Publication 9200.5-01 B
EPA/540/8-91/003
June 1991
The Superfund Program:
Ten Years of Progress
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
Washington, DC 20460
Printed on Recycled Paper
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Additional copies of this report may be obtained
from the National Technical Information Service
(NTIS) at:
NTIS
5285 Port Royal Road
Springfield, VA 22161
(703) 487-4650
11
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Table Of Contents
Executive Summary jv
Legislative And Regulatory Framework 1
Removal Actions 4
Site Assessment Activities 10
Remedial Activity 14
The Enforcement Program .....22
Public Participation In Decisionmaking 26
Roles Of States And Indian Tribes 30
Management Infrastructure 33
Future Directions And Challenges 36
EPA Superfund Offices 37
For More Information 38
Glossary Of Terms 40
111
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The Superfund Success Story
/„
The Superfund program is up and running, and the accomplishments have been many:
The legislative and regulatory framework
has been developed, tested and enhanced,
and today provides a solid blueprint for
Superfund program operations.
Removal actions continue to provide rapid
and flexible response to health and environ-
mental threats wherever and whenever they
occur.
More than 2,300 removal actions have been
started and more than 1,950 completed since
1980, making the removal program the most
rapidly productive component of Superfund.
EPA has revised its screening mechanism for
Superfund sites to portray more accurately the
degree of relative risk to both human health
and the environment at National Priorities
List sites.
EPA has met all measurable goals for
Superfund site assessment and inspection set
forth by Congress.
Permanent, cost-effective solutions to the
most serious hazardous waste sites have begun
at more than 1,000 remedial sites during the
last 10 years.
EPA has made remedial action a top priority;
today there are more sites in the construc-
tion pipeline than ever before.
Many of these remedies have used innova-
tive treatment technologies to reduce the
toxicity, mobility, or volume of waste.
The Agency uses a variety of enforcement
tools to encourage responsible parties to
settle, but still maintains authority to force
private party response when necessary. PRPs
now conduct more than 60 percent of
Superfund remedial actions.
EPA listens to citizen concerns and fully
involves the public in the Superfund
decisionmaking process "early, often and
always."
States, Territories, and Indian Tribes
continue to take lead responsibility for
Superfund response at many sites, and that
number is expected to increase significantly as
individual State hazardous waste programs
mature. For example, States have completed
more than 58 percent of preliminary assess-
ments and 32 percent of site inspections in the
Superfund program.
The Superfund program management sys-
tems and procedures are in place and are
continually being refined.
EPA's knowledge of how contaminants enter
and travel through environmental media has
increased, leading to better solutions to
complex waste management problems.
The Superfund program continues to improve
the quality of the program over time, building
public confidence.
The "One Superfund Program—Enforce-
ment First" concept has resulted in a seven-
fold increase during the last four years in
responsible party settlements with a total
value of $3.7 billion.
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Executive Summary
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Historical Goals
The Superfund program is one of
the nation's most ambitious and
complex environmental programs.
Launched in 1980, with the passage
of the Comprehensive Environmental
Response, Compensation, and
Liability Act (CERCLA),
Superfund's primary goal is to protect
human health and the environment.
This goal is achieved in several ways.
• First, CERCLA provides
unparalleled enforcement
powers based on the belief that
polluters should take responsi-
bility for cleaning up their own
wastes.
• Second, CERCLA's authority
for Federal response enables
EPA to protect human health
and the environment in the event
responsible parties do not take
timely, adequate action.
• Finally, CERCLA establishes a
Hazardous Substances Response
Trust Fund to cover the costs of
enforcement and cleanup
activities.
The Challenge
At the outset of the Superfund
program, EPA's primary challenge
was to respond to cleanup requests
while building an organizational
structure and staff, developing
program policies and guidance, and
accumulating money in the Trust
Fund to support program operations.
Today, EPA has a solid infrastructure
in place to manage
this complex program.
In ongoing efforts to
enhance its manage-
ment systems and
engineering capabili- _______^
ties, EPA is exploring
new frontiers in science and technol-
ogy. Total Quality Management
(TQM) approaches, which are
revolutionizing the business world,
are being implemented and EPA is
sharing with the public tangible
environmental improvements.
In 1989, the Administrator of
EPA completed a Management
Review of the Superfund Program
(commonly known as the 90-Day
Study). This review provides a
candid self-evaluation of past pro-
gram activities and achievements,
identifies conflicting mandates and
needs for program enhancements, and
makes a commitment to following a
practical plan for the future. This
plan is based on a set of eight strate-
gic goals:
• Control acute threats immedi-
ately. EPA will get into the
field fast, size up the scope of
the problem, and undertake
appropriate action right away to
ensure protection from immedi-
ate threats to people and the
environment.
• Emphasize enforcement. EPA
will encourage or compel
responsible parties to conduct
more site work to increase the
total number of cleanups.
• Address worst sites/worst
problems first. After attacking
the immediate threat, the
Agency will begin the earliest
remedial work to address
... the Agency has a clear plan for
the second decade of Superfund and
beyond...
problems that remain high
priority when compared to
competing problems at other
sites.
Monitor and maintain sites
over the long-term. EPA will
monitor Superfund sites over
the long-term to ensure that the
remedy remains protective of
human health and the environ-
ment.
Vll
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i Executive Summary
Develop and use new technolo-
gies. EPA will develop, demon-
strate, and use permanent
technologies to achieve final site
cleanups, to the maximum
extent practical.
Improve efficiency of program
operations. EPA will improve
the efficiency of program
operations by pursuing a "one
Superfund" approach to site
cleanup activity and enforce-
ment against polluters.
Encourage full public partici-
pation. EPA will increase the
role of citizens in Superfund
decisions and encourage clear
and consistent two-way commu-
nication with the public.
... resources are directed toward the
worst problems first to minimize risk
and maximize protection —
• Foster cooperation with other
Federal and State agencies.
EPA will work with State
agencies, natural resource
trustees, Indian Tribal Govern-
ments, and other Federal agen-
cies to ensure an effective and
cooperative relationship.
EPA developed these eight goals
based on the lessons learned during
the first 10 years of the program, and
will build upon those lessons to chart
the course for the future.
The Turning Point:
A New Strategy
From these goals, a strategy for
the next decade of Superfund has
emerged. Simply stated, that strategy
is to:
• Enforce aggressively
• Make sites safe
• Make sites clean
• Bring new technology to bear
in solving hazardous waste
problems.
The Superfund program's theme of
solving the worst problems at the
worst sites first is right in step with
the Agency's
overall policy for
prioritized risk
reduction. Under
this policy, re-
sources are directed
mmtmrnmrnmimmmmmmm* tOWard the WOrSt
problems first to
minimize risk and maximize protec-
tion of human health and the environ-
ment.
Today, a decade after CERCLA's
enactment, the guiding principles of
the original Superfund program
remain intact. In fact, the Superfund
Amendments and Reauthorization
Act of 1986 (SARA) adopted the
majority of policies and procedures
the Agency had developed during the
first 5 years of the program, and
provided a number of changes to
strengthen and fine tune the program.
In November of 1990, Congress
passed a 3-year extension of the
taxing authority for Superfund,
ensuring uninterrupted implementa-
tion of the program through 1994.
The Future Is
Built On The Past
EPA recognizes that the hazard-
ous waste problem in the United
States remains large, complex, and
long-term. There are no easy solu-
tions, but the Agency has a clear plan
for the second decade of Superfund
and beyond. EPA is conducting
studies that will help define the total
universe of Superfund sites, how
much it will cost to clean up those
sites, and the future role of enforce-
ment and States in reaching the
ultimate goal of protecting human
health, welfare, and the environment.
This 10-year perspective report is
designed to provide an overview of
Superfund program activities, to
illustrate the clear progress that has
been made in addressing uncontrolled
hazardous waste sites nationwide, and
to point the direction for the future of
the program.
Vlll
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Legislative And Regulatory Framework
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Rules And Tools
Superfund was created by
Congress in 1980 with the passage of
the Comprehensive Environmental
Response, Compensation, and
Liability Act of 1980 (CERCLA).
CERCLA arose out of the need to
protect citizens from the dangers
posed by abandoned or uncontrolled
hazardous waste sites. Most Ameri-
cans can remember nightly news
broadcasts in the late 1970s describ-
ing the thousands of leaking drums
and ground water threats discovered
at the Love Canal site in Niagara
Falls, New York. CERCLA gave the
Federal government broad authority
to respond to hazardous substance
emergencies, and to develop long-
term solutions for the nation's most
serious hazardous waste problems
like Love Canal.
The term "Superfund" referred to
a $1.6 billion Hazardous Substance
Response Trust Fund established to
pay for cleanup and enforcement
activities at waste sites. This fund
was financed primarily with a tax on
crude oil and 42 commercially used
chemicals. The tax supported the
concept that those responsible for
environmental pollution should
assume the cost. The original law
also enabled the Federal government
to recover the costs of its actions
from those responsible for the
problem, or to force them to clean up
the hazardous site at their own
expense.
On October 17, 1986, the
Superfund Amendments and Reau-
thorization Act of 1986 (SARA) was
enacted. SARA reflected EPA's
experience in administering the
complex Superfund program during
its first 6 years. The reauthorized
law made several important changes
and additions to the program:
• Increased the size of the Trust
Fund from $1.6 billion to $8.5
billion
• Stressed the importance of
permanent remedies and
innovative treatment technolo-
gies in cleaning up hazardous
waste sites
... those responsible for
environmental pollution
should assume the cost.
Established specific cleanup
goals and schedules
Required Superfund actions to
consider the standards and
requirements found in other
Federal and State environ-
mental laws and regulations
Expanded the statutory cost
and duration limits on removal
actions
Provided new enforcement
authorities and settlement tools
Increased State involvement
in every phase of the Super-
fund program
Increased the focus on human
health problems posed by
hazardous waste sites
Encouraged greater citizen
participation in making
decisions on how sites should
be cleaned up
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Legislative And Regulatory Framework
• Expanded research and train-
ing activities to promote the
development of alternative
and innovative treatment
technologies
• Required cleanup of Federal
facilities to meet Superfund
requirements.
In response to the tragic toxic
chemical release in Bhopal, India,
and a subsequent serious incident in
Institute, West Virginia, Congress
also established new reporting
requirements for facilities that
handle hazardous chemicals.
Title III of SARA, the Emergency
Preparedness and Community
Right-to-Know Act of 1986,
established a four-part program to
define an emergency planning
structure at the State and local
levels; require emergency notifica-
tion of hazardous chemical releases;
require notification of chemical use,
storage, or production activities;
and define annual emissions report-
ing requirements.
The Superfund response effort
is guided by the National Oil and
Hazardous Substances Pollution
Contingency Plan, commonly
referred to as the National Contin-
gency Plan (NCP). This plan
outlines the steps that EPA, the U.S.
Coast Guard, and other Federal
agencies must follow in responding
to situations in which hazardous
substances or oil are released into
the environment. Fourteen Federal
agencies are members of the
National Response Team (NRT),
which is responsible for planning
and coordinating preparedness and
response actions.
The NCP, which actually
predates Superfund, was originally
written to implement provisions in
the Clean Water Act having to do
with spills of oil and hazardous
substances into navigable waters. It
has been revised three times: first to
incorporate the 1980 Superfund
program, then later in 1985 to
streamline the Superfund process,
and most recently in March 1990 to
address significant changes in the
Superfund program resulting from
the enactment of SARA. The NCP
is currently being revised to include
the new requirements of the Oil
Pollution Act of 1990.
The national goal described in
the NCP is to select remedies that
are protective of human health and
the environment, that maintain
protection over time, and that
minimize untreated waste. The
Superfund program expects to
achieve this goal in several ways:
• Use treatment technology on
principal threats, wherever
practical
• Consider isolation and contain-
ment for wastes posing mini-
mal threats or where treatment
is impractical
• Combine treatment with
containment, as necessary
• Supplement engineering
solutions with institutional
controls such as deed restric-
tions wherever appropriate
• Consider innovative treatment
technologies
• Return ground waters to their
beneficial uses as soon as
possible.
The Superfund Process
The process established by the
NCP for meeting these expectations
and handling hazardous waste
problems begins with learning where
a hazardous waste site might exist
(see Superfund Process Flowchart,
Figure 1). If, based on a preliminary
\ Two Types Of Response: Removal And Remedial Actions
1 1 t» f>* b 7 m. »
C Every Superfund site is unique, and cleanups must be tailored to the specific needs
i of each site or release of hazardous substances. From the beginning of the process,
jr EPA makes a concerted effort to encourage those responsible to pay for cleanup.
t However, if an immediate problem threatens human health, welfare, or the environ-
• ment, EPA" will take acgo"n~ EPA'can'respond to hazardous substance releases in
; two ways as defined by CERCLA: •
Removal Actions—short-term actions which stabilize or clean up a hazardous
site that poses a threat to human health or the environment. Typical removal
actions include removing tanks or drums of hazardous substances from the
surface, excavating contaminated soil, installing security measures at a'site, or
providing a temporary alternate source of drinking water to local residents.
Remedial Actions—the study, design, and construction of longer-term and
usiially more expensive actions aimed at permanent remedy. EPA can take
remedial actions only at sites on the National Priorities List (NPL)—EPA's list
of the nation's most serious hazardous waste sites. Typical remedial actions
includelernQYlng buried drums from a site, constructing underground walls to/
1 control the movement of ground water, incinerating wastes, or applying
bioremediation techniques or outer innovative technologies to contaminated
soil.
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Legislative And Regulatory Framework
sms&ssm
evaluation there is an emergency
requiring immediate action, the next
step is to act as quickly as possible
to remove or stabilize the threat.
These actions are known as remov-
als (see box on previous page).
Even after the necessary emer-
gency action has been taken to
control the immediate threat, in
some cases contamination may
remain at the site. A more detailed
analysis of the contamination may
be necessary to determine if further
work needs to be done to find a
permanent solution at the site. If
long-term action is necessary, a
decision must be made regarding the
relative national priority of that
particular site. These long-term
actions are known as remedial
actions (see box on previous page).
An investigation of the extent of
contamination and analysis of the
range of alternative remedial actions
Superfund might take is then con-
ducted. Concerns of the State and
local community are seriously
considered in determining which
alternative to select. Efforts also are
Figure 1
Superfund Process Flowchart
Continuous
Enforcement
Efforts
Site Discovery
Preliminary Assessment (PA)/
Site Inspection (SI)
Hazard Ranking System (HRS)/
National Priorities List (NPL)
Remedial Investigation (Rl)/
Feasibility Study (FS)
Continuous
Public
Participation f"
Selection of Remedy
Removal Action
'*, At Any Point,
• As Necessary
Remedial Design (RD)
Remedial Action (RA)
Operation and Maintenance (O&M)
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NPL Deletion
made to find individuals or compa-
nies responsible for the contamina-
tion and make them pay for and/or
conduct the cleanup.
After the remedial action has
been selected, it must be designed
and constructed. Once action has
been completed, the site often must
be monitored and maintained, a
responsibility which is assumed by
the State or responsible party.
Typically, a Superfund cleanup
action follows this sequence of
events, but not always. For ex-
ample, an emergency requiring
immediate attention can occur at a
site which already is undergoing a
long-term remedial action.
At all stages of response, work
can be done by a State or EPA using
the Trust Fund, or by responsible
parties as a result of enforcement
efforts. In addition, community
relations activities and enforcement
actions take place throughout the
cleanup process to ensure optimal
use of Trust Fund resources and the
involvement of all interested parties
in the decisionmaking process.
The following sections of this
report examine in detail each step of
the decisionmaking process for
Superfund removal and remedial
responses, highlight the major
accomplishments in each program
area, and provide an overview of
new Superfund program initiatives.
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Removal Actions
Fires, explosions, contaminated
drinking water, and toxic fumes.
These are just some of the situations
the removal program regularly
confronts. When there is no time for
lengthy analysis of a hazardous
substance release and no one else is
available who has the technical and
financial capability to respond,
Superfund removal program person-
nel are on the scene responding as
quickly as possible to reduce imme-
diate threats to human lives and the
environment.
The removal program has been
the most rapidly productive compo-
nent of the Superfund program, with
more than 2,300 cleanups started
and 1,900 cleanups completed since
1980 (see Figure 2). Virtually every
day in 1990, a removal action was
started somewhere in the U.S. and
its territories. That rate has been
remarkably consistent since 1987
when the Superfund Amendments
and Reauthorization Act (SARA)
doubled its limits on time and cost
for removals to 12 months and $2
million. While remedial actions are
usually more expensive, extensive,
and often receive more media
coverage, the removal program has
been a key contributor to the overall
success of the Superfund program in
responding to hazardous substance
threats across the country.
Removal actions are taken at
all types of sites including inactive
waste facilities such as open dumps
or landfills that have been closed
... the most rapidly
productive component
of the Superfund
program.
I -_ _ -
~A removal action provides a rapid and flexible response to reported health and
{environmental hazards, wlierever and whenever they occur. Removals are:
*
f,F
jp,
frt
Investigated and assessed within hours of being reported, 24 hours a day,:
"~ "365 days a year
III II I II II 111 I I I III 11111 III Illll III II II IE I II Mi I Him "IHIl " «k" WIIPNIMM'I
Conducted at both KationafPnbrities List (MPL) arid non-NPL sites'
%
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l!
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• Conducted by On-Scene Coordinators (OSCs) from EPA or the U.S.
„, Coast Guard (USCG)
• Kept consistent with any potential long-term remedial actions
Limited, unless specially exempted, to 12 months for completion and $2
^million in costs.
Figure 2
Removal Action Starts and Completions*
2400
2200
2000
£ 1800
1600
|
I
I
1400
1200
1000
800
600
400
200
Removal Action Starts
Removal Action Completions
" 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990
Fiscal Year
* Totals are for combined EPA, U.S. Coast Guard, and Potentially Responsible Party-lead removal actions
down or abandoned; "midnight
dumps" where drums or other con-
tainers have been illegally disposed
of in secluded woods, open fields, or
other locations; active manufactur-
ing or waste disposal facilities,
chemical manufacturers, and operat-
ing landfills; and transportation-
related accidents such as toxic
chemical releases from derailed
trains or overturned trucks. Cover-
ing a wide range of situations,
removal actions typically include a
variety of substances and health and
environmental threats. For example,
removal actions address threats to
communities and ecosystems from
fire and explosion; human direct
contact risks due to drinking water
or soil contamination; improper
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Removal Actions
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storage of hazardous substances in
drums, tanks, and other containers;
and deterioration of site conditions
due to bad weather. Generally,
removal actions include one or more
of the following activities:
• Evacuating or temporarily
relocating people to protect
human health
• Stabilizing or detonating
hazardous materials to prevent
fires and explosions
• Providing site security—signs,
fences, guards—to limit access
and prevent direct contact with
hazardous substances
• Providing an alternate water
supply
• Containing, removing, or
treating hazardous substances
by:
- Controlling drainage
- Stabilizing berms or dikes
- Closing or draining lagoons
- Capping soils or sludge
- Excavating and removing
contaminated soil
- Removing drums or other
containers
- Using chemical stabiliza-
tion.
While remedial actions require
that a site be on the NPL, removal
actions do not. To date, 29 percent
of all completed removal actions
have taken place at NPL sites; 71
percent have involved non-NPL
sites.
Of the 351 removal actions
begun in 1990, about two-thirds
were managed directly by EPA
Regional offices. The remainder
were managed either by the USCG,
which has responsibility for oil
discharges and hazardous substance
releases in coastal waters and some
inland waterways, or by potentially
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Removal Actions
Figure 3
Overview of Removal Process
Notification
or
Discovery
*
Conduct Removal
Site Evaluation (RSE)
*
Assess RSE results
against removal action
criteria in NCP
Meet Criteria End response or refer
program (if appropriate)
X Meets Criteria
Obtain approval for
removal action
A
T
Initiate site action
*
Oversee cleanup
contractors
1
Action completed
j " " | Public Participation 1
1 Ongoing Enforcement |
_ I
responsible parties (PRPs), whose
cleanup activity is monitored by
EPAorUSCG. In light of
Superfund's increased emphasis on
enforcement, it is significant that the
number of PRP-managed removal
actions has steadily increased,
accounting for 98 of the 351 starts in
1990.
Organization And Proce-
dures For Rapid Response
The National Response Center
(NRC), operated by the USCG in
Washington, D.C., is the official
clearinghouse for all reports of oil
and hazardous substance releases.
The Comprehensive Environmental
Response, Compensation, and
Liability Act (CERCLA) requires
that any manufacturer, waste facility
operator, or common carrier imme-
diately report releases of hazardous
substances (above substance-specific
thresholds known as "reportable
quantities") to the NRC.
When the release or potential
release is from an inactive waste
facility or from an illegal dump,
however, reporting is less routine.
The amount of the release—and
even the substance being released—
may not be known immediately, and
the NRC may receive only partial
information from State or local
public safety officials or the general
public.
Whether information is com-
plete or partial, the NRC alerts the
appropriate EPA or USCG Regional
OSC as well as State officials and
other Federal agencies with a
potential interest. The NRC also
alerts the EPA Emergency Response
Division in Washington, D.C.,
which sets policy for and manages
the removal program; but the NRC's
primary responsibility is the imme-
diate notification of the designated
Regional OSC. OSCs are on call 24
hours a day to respond to reports of
releases that may require a Super-
fund removal action.
The first task of the OSC may be
to assist public safety officials in
their efforts to protect the public.
This may include emergency efforts
to secure the site, ensure fire control,
provide emergency alternate water
supplies, or assist in temporary
evacuation.
-------
Removal Actions
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After public safety has been
secured, the OSC begins a removal
site evaluation. The objective is to
determine the potential for or source
of the release, the threat to human
health, whether another party is
conducting a proper response, and
the appropriate course of action.
Regional and National Response
Teams are available to provide
technical assistance to the OSC
during this evaluation. With this
assistance, the OSC is responsible
for documenting the situation and
determining whether a short-term,
relatively low-cost response—a
removal action—is sufficient to
stabilize or clean up the site.
If the OSC determines that the
situation does not require a removal
action, the site may be referred to
the Hazardous Site Evaluation
Division of EPA to be evaluated for
inclusion on the NPL and possible
remedial action, or it may be re-
ferred to another interested Federal
or State agency for action.
While the site is being evalu-
ated, the OSC also must determine
whether one or more PRPs are
capable and willing to assume
responsibility, under EPA supervi-
sion, for the appropriate course of
action. If the PRPs are unknown,
unwilling, or incapable of assuming
timely responsibility, the OSC
initiates a CERCLA-funded removal
action. Identified PRPs are not
released from responsibility, how-
ever. Throughout the course of the
removal action, the OSC or enforce-
ment personnel continue efforts for
PRP involvement and cost recovery.
Throughout the planning and
execution of a removal action,
opportunity for public participation
is mandated by CERCLA. Informa-
tion must be provided and public
response solicited. Only the require-
ments of public safety are allowed to
override this policy. Figure 3, on
the previous page, presents an
overview of the removal process.
New Directions For The
Removal Program
The most sweeping changes to
the removal program have occurred
as a result of expanded statutory and
regulatory authorities. Among the
most significant changes imple-
mented as a result of SARA, and
reflected in subsequent revisions to
the National Oil and Hazardous
Substances Pollution Contingency
Plan (NCP), are:
• Expanded response author-
ity: The limitations on removal
actions were increased from 6
to 12 months, and from $1
million to $2 million, to reflect
actual time and cost constraints
encountered during the first 6
years of the program. These
expanded limits increase the
flexibility of the removal
program to respond to various
threats and help achieve greater
coordination with the remedial
program.
• Contribution to remedial
performance: Removal
actions must be designed to
contribute to the efficient
performance of any subsequent
long-term remedial action.
-------
Removal Actions
: Expanded Authority And State-Of-The-Art Technology
Southeastern Wood Preserving in downtown Canton, Mississippi operated from
1928 until early 1979, when its owners filed for bankruptcy and abandoned the
site, gPA initiated an emergency removal action in June 1986 to stabilize three
: unlined, over-flowing surface impoundments containing creosote sludge and
: jiV'ater! Thirty-thousand gallons of water were pumped from the flooded areas of
-, the site. EPA proposed that the second phase of cleanup consist of either on-site
iiOQatmiknt or off-site disposal of the stabilized sludge.
;ln December 1988, the Department of Agriculture's Soil Conservation Service
(SCS) contacted EPA. While surveying a creek that borders the site, SCS had
noticed oily waste leaching into the creek. Through an Interagency Agreement,
SCS worked with EPA to excavate the contaminated soils.
In August 1989, EPA approved an exemption from the 12-month statutory limit on
removal actions. The Region approved additional funds to continue excavations
' "and to conduct pn-site treatment of the contaminated sludges. The sludges
sjhreMe.O to contaminate soil and drinking water (a municipal well is within 100
fleetof the§!!$}andcontjjyjeleaching into the creek (children playing in a park a
mile downstream from the site have complained of creosote burns). EPA is
proposing to use biological remediation to treat the 8,000 cubic yards of contami-
initcd soil left on the site. In August 1990, the EPA Region obtained an exemption
from the $2 million statutory limit to cover additional costs to meet stringent land
'disposal and air emission standards. Bioremediation is scheduled to begin in 1991.
Use of alternative technolo-
gies: When possible, EPA
considers cost-effective re-
moval action alternatives that
use recycling or treatment of
waste rather than land disposal.
This requirement promotes the
use of cleanup technologies that
reduce the toxicity, mobility, or
volume of waste.
• Compliance with applicable
or relevant and appropriate
requirements (ARARs): On-
site removal activities are
expected to identify and .
comply with all Federal (be-
yond CERCLA) and State
environmental and human
health laws to the extent
possible given the circum-
stances of the removal. This
ensures that removal actions are
conducted in a way that best
prevents damage to human
health, welfare, and the envi-
ronment.
• Off-site disposal: If a removal
action requires off-site disposal
of hazardous wastes, those
wastes must be sent to environ-
mentally-sound (RCRA-
approved) facilities. This helps
to ensure that wastes from
removal actions will not create
future Superfund sites.
These changes in authority and
program emphasis have increased
the removal program's flexibility to
respond to hazardous substance
releases while also promoting
environmentally sound technologies
and practices that reduce threats to
human health and welfare. The
removal program continues to
evolve in its flexibility and respon-
siveness as the Agency endeavors to
control immediate threats to people
and the environment.
Recently, the Superfund Man-
agement Review set forth a compre-
hensive, long-term strategy for the
Superfund program. Three elements
of the eight-part strategy have
especially important implications for
the removal program:
-------
Removal Actions
• Control acute threats immedi-
ately
• Address the worst sites and
worst problems first
• Emphasize enforcement to
induce private party cleanup.
Progress towards these goals had
already begun within the removal
program prior to the Superfund
Management Review. For example,
the Regions expanded an evaluation
effort already underway concerning
the need to control acute threats
immediately at existing NPL sites.
EPA also established timeframes for
conducting assessments at newly
proposed NPL sites and for follow-
up. Additionally, EPA is focusing
on methods to accelerate response at
NPL sites that use removal and
remedial program coordination to
make sites safer and address the
worst sites first. While the majority
of threats at NPL sites are addressed
through the remedial program,
certain sites may benefit from the
flexibility and streamlined response
options offered by the removal
program. Finally, EPA is emphasiz-
ing a strong "enforcement first"
approach for the Superfund program
in order to promote more private
party cleanups through the use of
enforcement and settlement authori-
ties.
The strength of the removal
program lies in its ability to mobilize
expertise and resources to respond to
immediate, critical hazardous
substance threats. Remedial actions
often receive more attention, as local
sites are scored and evaluated for
inclusion on the NPL. They also
Figure 4
Enforcement-Lead Removal Actions *
600
1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990
Fiscal Year
* Figures shown are for enforcement-lead removal action starts at NPL and non-NPL sites.
generally receive more resources, as
long-awaited, full cleanups are
planned and implemented. But the
removal program is fast, flexible,
and operates whenever and wherever
a release or a potential for a release
of hazardous substances poses a
threat to human health, safety, or the
environment.
The increase in cost limits for
removal actions does not mean, of
course, that the removal program has
been exempted from national and
EPA fiscal constraints. Priorities
have been set—addressing immedi-
ate threats at NPL and non-NPL
sites first. Less immediate threats at
NPL sites will be addressed only as
resources permit. Enforcement has
steadily improved, as well. Overall,
there were 98 PRP-led removal
actions in 1990, up from 47 in 1986.
Enforcement is now making it
possible to address a greater number
of sites each year (see Figure 4).
Over the last 10 years, the
removal program has developed an
organization and procedures in
keeping with its mission. It has been
able to maintain the speed and
flexibility of a decentralized pro-
gram while cultivating crucial health
and safety expertise. The expanded
response authority granted under
SARA is not only an indication of
rising response costs but an ac-
knowledgment of the importance of
the program within Superfund. The
removal action program has been
successful in creating an effective
EPA presence at non-NPL sites and
in stabilizing and mitigating the
worst problems at NPL sites until
the remedial program can implement
complete cleanups.
-------
Site Assessment Activities
The primary goal of the site
assessment program is to identify
the most serious hazardous waste
sites in the nation and list them on
the National Priorities List (NPL), a
catalogue of those sites with a
potential need for remedial action.
Site assessment is the initial phase of
Superfund response, and the process
by which EPA and the States
identify, evaluate, and rank hazard-
ous waste sites. Within this frame-
work, however, specific objectives
for the program have shifted over
the course of Superfund's 10-year
history. In part, this is because the
scope and magnitude of the problem
of neglected hazardous waste sites
was vastly underestimated when the
Superfund program began.
The Superfund program was
originally conceived as a 5-year
effort that would address the 400
worst abandoned hazardous waste
sites in the nation, and gradually be
phased out of existence. Since 1980,
however, it has become clear that
the total number and distribution of
hazardous waste sites far exceeds
any of the original estimates.
Between 1980 and 1986, the
major emphasis for the site assess-
ment program was on establishing
program requirements and develop-
ing the Hazard Ranking System
(HRS), which enables EPA to
evaluate numerically the relative risk
of each site listed in the Comprehen-
sive Environmental Response,
Compensation, and Liability Infor-
mation System (CERCLIS), the
official information system for the
Superfund program. EPA then
established a cut-off point for sites
that would be eligible for Federal
cleanup funds. It was the Agency's
goal at that time to place a minimum
of 400 of the nation's worst sites on
the NPL, based on their HRS scores.
With the 1986 enactment of the
Superfund Amendments and Reau-
Ihorization Act (SARA), Congress
tSite assessment activities help identify and assess the most serious hazard-
Efous Waste sites in the nation. These activities include the following steps:
$_, • . Site discovery—identifying hazardous substance releases through
1 formal and informal channels
Preliminary assessment (PA)—evaluating existing site-specific
data for early determination of need for further action
Site inspection (SI)—assessing on-site conditions and characteris-
tics to determine if an HRS score should be developed
Hazard Ranking System (HRS) scorer—applying a mathematical
approach to assessment of relative risks posed by sites
NPL listing—determining those sites that are eligible for Superfund-
financed remedial action.
developed measurable goals for the
Superfund site assessment program.
Specifically, SARA mandated that
for all sites listed in CERCLIS as of
October 17, 1986, preliminary
assessments (PAs) must be com-
pleted by January 1, 1988, and site
inspections (Sis) must be completed
by January 1, 1989. In addition,
SARA required that EPA revise the
HRS to emphasize potential human
health risks and damage to ecosys-
tems. These changes demonstrated
that a new emphasis was being
placed on the site assessment
program, not just as a preliminary
phase to the remedial program but as
a rigorous screening program
designed to determine which sites
should continue through the process
to NPL listing. The site assessment
program is critical because once a
site is listed on the NPL it becomes
eligible for Federal cleanup funding.
10
-------
Site Assessment Activities
Since 1986, 10,700 sites have
had PAs and 6,300 of these sites
have undergone Sis. The NPL,
which began in 1981 as an "Interim
Priorities List" of 115 sites, now
Congress developed measurable
goals for the Superfund site
assessment program.
locating sites that would otherwise
go unnoticed. For example, Region
X has an active site discovery
program that uses geographic
information systems and makes use
of historical indus-
«_______ trial business lists
and EPA program
lists to identify
sensitive or vulner-
able areas where
releases would be
significant.
contains nearly 1,200 sites. Based
on past rates of listing, the Agency
expects to list approximately 100
sites per year. The NPL will likely
contain 2,100 sites by the year 2000.
The Site Assessment
Process
Site Discovery
EPA learns of releases that
potentially warrant Superfund
response through both formal and
informal channels. The Comprehen-
sive Environmental Response,
Compensation, and Liability Act
' (CERCLA) notification require-
ments mandate that any person who
knows of a hazardous substance
release notify the Federal govern-
ment. Moreover, under SARA,
owners or operators of facilities that
produce, use, or store extremely
hazardous substances are required to
notify the local emergency planning
committee and State emergency
response commission if at any time a
release exceeds reportable quanti-
ties, as described in the Removal
chapter.
In addition to these mandatory
reporting requirements, EPA has
also relied on public petitions and
informal citizen reports to learn
about existing or potential hazardous
waste sites. From time to time,
Regions have taken an active role in
Preliminary Assessments
The first step the Agency takes
after learning of a potential site or
release is to obtain and review all
available reports and documentation
about the site. As originally con-
ceived, the PA was a desk-top
evaluation of existing site-specific
data designed to determine whether
a site merits further action under
CERCLA.
Recently, however, the scope of
the PA has been expanded to
provide more information and
expedite the decisionmaking pro-
cess. The expanded PA, which
includes site reconnaissance and a
projected numerical rating for the
relative hazards posed, enables EPA
to identify priorities more accurately
and consistently, and allows for
early identification of sites that need
no further action by the Federal
government.
About half of all sites are
eliminated from further CERCLA
consideration at this step, with a
decision of no further remedial
action planned (NFRAP). Sites that
present a clear and immediate
danger to human health and the
environment and, therefore, require
immediate action may be referred to
the Superfund removal program.
Other sites may be referred to other
environmental programs, as appro-
priate. The remaining sites move on
to the SI stage in the site assessment
process. Approximately 5 percent of
those sites receiving an HRS score
go on to be included on the NPL. At
any stage in the site assessment
process, a site may be referred to the
removal program, referred to
another environmental program, or
determined to need no further action.
As of January 1990, 94 percent
of the 33,000 sites currently in
CERCLIS have been assessed,
meaning that more than 31,000 PAs
have been conducted over the course
of Superfund's 10-year history. To
prevent a backlog, and to comply
with the intent of SARA, EPA's
policy is to conduct a PA within 1
year of a site's listing in CERCLIS.
Site Inspections
If the preliminary assessment
indicates a suspected release of
hazardous substances that may
threaten human health or the envi-
ronment, EPA requires an inspec-
tion. The purpose of the SI is to
investigate the site firsthand and
determine if an HRS score should be
developed. The inspection begins
with a site visit and sample collec-
tion to define and characterize
further the problems at a site. The
primary objective of this in-depth
assessment of site characteristics is
to collect sufficient information to
document an HRS score to the
extent required for NPL listing. At
times, an expanded site inspection
has been necessary to fill data gaps
and to serve as a bridge between the
site assessment and remedial proc-
esses.
Approximately 12,800 Sis have
been conducted since Superfund's
inception. Figure 5 presents a
summary of accomplishments in the
site assessment program.
11
-------
• Site Assessment Activities
Figure 5
Historical Superfund Site Assessment Accomplishments
5,000 -
Sites in CEHCLIS
PA Total to Dale
SI TWal to Data
33,000
Sis
13,000
1980 1981 1982 1983
1984 1985 1986
Fiscal Year
1987 1988 1989 1990
Hazard Ranking System
In response to a CERCLA
mandate to establish a screening
mechanism, EPA developed a
mathematical approach to rate the
hazards of sites. This model, known
as the HRS, enables EPA to assess
the relative risk posed by sites in the
CERCLIS data base, and thereby
determine which sites should be
listed on the NPL, To evaluate risk,
the original HRS examined three
pathways of exposure: ground water,
surface water, and air. A composite
score for each site was developed by
considering three factors for each
pathway: likelihood of release,
waste characteristics, and targets.
EPA develops and refines the
score at each step of the site assess-
ment process, with the percentage of
hard data increasing as more
samples are taken. The score at each
stage of the process determines
whether or not a site will continue to
be considered for inclusion on the
NPL.
A revised HRS (rHRS) was
proposed in December of 1988, and
finalized in December of 1990. The
system was revised to portray more
accurately the degree of relative risk
to both human health and the
environment. The key changes in
this revision take into account, to the
extent possible:
• The population at risk
• The potential for drinking water
contamination
• The potential for direct human
contact
• The potential for ecosystem
destruction
• Damage that may affect the
human food chain
• Actual or potential contamina-
tion of ambient air.
The rHRS affects every stage of the
site assessment process. The
purpose of the HRS, however,
remains unchanged. It remains a
screening tool used to evaluate a
site's risk and determine its eligibil-
ity for the NPL. The HRS score
does not, however, provide an
indication of the feasibility, desira-
bility, or nature of the cleanup action
that will ultimately be undertaken.
NPL Listing Process
Sites of hazardous releases must
be included on the NPL in order to
be eligible for Superfund-financed
remedial action. The listing of sites
on the NPL is accomplished in one
of three ways. The most common is
for the site to score at least 28.50 on
the HRS. Second, each State is
given the opportunity to designate
12
-------
Site Assessment Activities
vr'>•"'.:
one site, which it considers its
highest priority, for the NPL.
Although less frequently used, the
third approach is to list sites for
which the Agency for Toxic Sub-
stances and Disease Registry
(ATSDR) has issued a health
advisory, that EPA determines pose
a significant threat to human health
and that EPA expects will be more
effectively addressed under the
remedial program, as opposed to
using its removal authority.
The promulgation of the revised
HRS is perceived as an opportunity
to implement far-reaching changes
in the NPL listing process and to
incorporate Total Quality Manage-
ment (TQM) tenets into the process.
The primary goal is to move sites
from discovery to listing in the 4-
year timeframe mandated by SARA.
The change most visible to the
general public will be the publica-
tion of two NPL Updates per year.
These offer the public an opportu-
nity to comment on a site and
receive responses from EPA, before
actually placing the site on the NPL.
Site Assessment
Accomplishments
The Agency has made substan-
tial progress in the past few years in
standardizing and streamlining the
site assessment process. These
efforts have resulted not only in an
overall improvement in the quality
and timeliness of assessment activi-
ties, but also in more effective State
involvement and greater consistency
nationwide.
13
-------
Remedial Activity
The Superfund remedial pro-
gram has evolved into a mature,
revitalized program aimed at prompt
action to address threats to human
health and the environment. Once
EPA places a site on the National
Priorities List (NPL), it becomes
eligible for long-term remedial
activity. Cleaning up these sites is a
long, complex process that may take
millions of dollars and many years
to complete. Remedial sites typi-
cally have multi-media contamina-
tion (soils, surface water, ground
water) by many different types of
chemicals. The sites often must be
broken up into several individual
projects to address all of the prob-
lems at the site, which may encom-
pass acres, or even miles. EPA is
developing new, innovative tech-
nologies to provide permanent, cost-
effective solutions at NPL sites.
The Remedial Process
The 1986 amendments to the
Comprehensive Environmental
Response, Compensation, and
Liability Act (CERCLA) brought
new challenges to the remedial
program. EPA now strives toward
permanent remedies using alterna-
tive technologies to land disposal to
protect human health and the
... an established, action-oriented program for
cleaning up the highest priority sites.
Remedial actions at NPL sites
provide permanent, cost-effective
solutions to the most serious
hazardous waste sites. The primary
goals of the remedial program are
to;
• Protect human health and the
environment
• Address worst sites/worst
problems first
• Emphasize permanent reme-
dies using innovative treat-
ment technologies.
I
environment. EPA is meeting this
challenge by creating systems for
information exchange, technology
development programs, and a
streamlined remedial process that
has addressed more than 1,000
remedial sites during the last 10
years.
The remedial process is com-
plex, requiring extensive data
gathering and analysis to character-
ize the scope of the problem and
potential threats to human health and
the environment, and to develop and
implement workable solutions to the
Figure 6
The Remedial Process
Remedial Investigation (Rl)
An assessment of the nature/and extent of :contamination;
and the associated health and environmental risks.
Feasibility Study (FS)
Development and .analysis of the range of cleanup alternatives for the
site, according to the nine evaluation criteria; usually undertaken
concurrently with the Rl
V
Selection of Remedy
Selection of the remedial alternative for the. site.: This step includes;
Proposed Plan
Identifies the remedial alternative 1 kely to be chosen'for a Superfuhd
site and explains why it is the preferred alternative, arid, altows
for public comment
Record of Decision (ROD)
The official report documenting the background information on. the site
and describing the chosen remedy and how it was selected
|
Remedial Design (RD)
Preparation ,of technical plansand specifications
for implementing the chosen remedial alternative
1
Remedial Action (RA)
Construction or other work necessary to
implement the remedial alternative
*
Operation & Maintenance (O&M)
Activities conducted at a site after a response action occurs
to ensure that the cleanup methods, are working properly and
to ensure site remedy continues to be effective
14
-------
Remedial Activity
problem. During the first phase of
the remedial process, the approach
to eliminating, reducing, or control-
ling risks at the site is conceived,
evaluated, and selected. Once this
remedy is approved, it is designed,
implemented, and monitored. The
five major steps that make up the
remedial process are shown in ,
Figure 6. Developing a workable,
permanent solution for a hazardous
waste site requires care—and
involvement from the community—
at each step of the process. The
overall remedial program goal is to
select a remedy that reduces or
eliminates the risks to people and the
environment, now and in the future.
Although the majority of
remedial activity in the past has been
funded through the Trust Fund, EPA
is aggressively pursuing responsible
parties to undertake and finance the
cleanup activities. Responsible
parties now conduct more than 60
percent of remedial actions, and that
percentage is expected to continue to
increase. In some cases, the respon-
sible parties clean up the sites
voluntarily, under the supervision of
EPA or the State. If no responsible
fe:
parties have been found, or if there
are problems getting them to act,
EPA will proceed using Trust Fund
monies and recover costs later.
The State may decide to conduct
and finance the cleanup by itself, or
may enter into a Cooperative
Agreement with EPA whereby the
State undertakes certain remedial
activities financed by the Fund. In
either case, EPA provides oversight
throughout the remedial action.
While the Hazardous Site Control
Division at EPA Headquarters
manages the overall remedial
program, the Remedial Project
Managers (RPMs) in each EPA
Region provide the day-to-day
direction and oversight of site
activity. Whether EPA or the State
has the lead in cleaning up a site,
CERCLA requires that the State
contribute 10 percent of the cleanup
costs for sites that were privately
owned or operated and 50 percent of
costs for sites that were owned or
operated by the public. In addition,
once EPA and the State have
certified that the remedy is working
properly, the State finances further
operation and maintenance.
Remedial Investigation
Once a site is placed on the
NPL, the lead agency must further
assess the site problems. Similar to
the initial site inspection prior to
listing on the NPL, this involves an
examination of site characteristics in
order to better define the problem.
The remedial investigation (RI),
however, is much more detailed and
comprehensive than the initial site
inspection. The RI is designed to
define the nature and extent of the
problem and to provide information
needed to develop and evaluate
cleanup alternatives. It is carried out
by a team of health and environmen-
tal scientists to determine the
existence and nature of any actual or
potential threat that may be posed to
human health or the environment,
and defines the boundaries or extent
of any contamination found at a site.
The Stauffer Chemical example (see
box, next page) illustrates the
complexity of site problems and data
collection needs.
Feasibility Study
EPA develops more than one
possible approach for Superfund
remedial action at a site, and care-
fully compares the advantages and
disadvantages of each approach.
These analyses of alternatives are
called feasibility studies (FSs).
In an FS, environmental engi-
neers and other technical staff
consider, describe, and evaluate
options for cleaning up the site,
using the data collected in the RI as
a basis and collecting additional
information as needed. Once the
cleanup alternatives are defined, the
feasibility study examines each
alternative according to nine criteria,
and portrays their effectiveness. The
kinds of questions an FS answers
are:
15
-------
Remedial Activity
1. Overall protection of human
health and the environment.
Will the remedy protect human
health and the environment;
how are risks eliminated or
controlled by the remedy?
2. Compliance with applicable
or relevant and appropriate
requirements (ARARs). Does
the remedy meet all of the
applicable requirements of
State and Federal environ-
mental laws and regulations?
These first two criteria are catego-
rized into a group called "threshold
criteria" because they are the
minimum requirements that each
alternative must meet to be eligible
for selection as a remedy. After
these criteria are applied, the FS
reviews:
3. Long-term effectiveness and
permanence. Does the remedy
protect human health and the
environment over time?
4. Reduction of toxicity, mobil-
ity, or volume. How well do
the treatment technologies
perform in reducing the threats
at a site?
5. Short-term effectiveness.
How well are the community
and cleanup workers protected
during the remedial action?
6. Implementability. What is the
technical and administrative
feasibility of a remedy, includ-
ing the availability of materials
and services needed to imple-
ment the chosen solution?
7. Cost. How much will the
remedy cost, including esti-
mated capital (e.g., supplies
and equipment, and contractor
costs) and operation and
maintenance costs?
i Remedial Investigation At Stauffer Chemical
* The Stauffer Chemical site in Mobile County, Alabama, was the location of
• chemical company operations from two adjacent plants. Waste from the plants
r- included plant refuse, used samples, and solid wastes containing a variety of
; herbicides and pesticides. The waste was placed in unlined landfills and waste
•- ponds, some of which drained into a local pond. The disposal practices at both ,
s sites contributed to ground water contamination. The owners installed moni- ;
: toring wells and a system to treat the ground water in/the 1970s. Because the. :
J ground water was not getting cleaner, in 1982 the State installed monitoring '
: wells, data from which formed the basis for EPA placing the site on the NPL. ;.
. EPA then Lnformed the previous owner that an Rlmust be initiated at the site. >
I During the RI, EPA examined the type and extent of the contamination on the,
surface, and how the ground water was affected by the site contamination. The
surface contamination ,was characterized by sampling of soils around the
landfills and ponds and sampling of the liquids in tne ponds and other surface
water in the area. Toinvesugate"nie"ground[ watercb'nSmin^bn,l"iSPX'™"""""" '•• ">
sampled and analyzed the data from more than 40 water and monitoring wells.
The results of the ..RI showed a range offRreats, including grounfl water
contaminated with carbon tetrachloride and other contaminants, ponds contain-
ing contaminated soils and sludges, landfills containing a combination of
wastes that could be leaching into the ground water, and mercury detected in
the sediments of a nearby wetland.
i
•in
Based on the RI, EPA had the information it needed to develop alternate
solutions to the problems posed by the site. EPA discovered what contami-
nants existed, where they were located, and the level of contamination in-each
area. It was a long, difficult task of collecting the needed information. It took
more than 3 years from when EPA informed the previous owner of the site that
an RI was necessary to when the RI report was completed. During the final
phases of the RI, however, EPA began to conduct the next step in the remedial
process, the feasibility study.
16
-------
Remedial Activity
Evaluation criteria 3 through 7 are
known as the "primary balancing
criteria" that are used to identify
major trade-offs among the alterna-
tives. The last two criteria are:
8. State acceptance. Does the
State concur with, oppose, or
have no comment on the
preferred alternative?
9. Community acceptance.
Does the affected community
concur with, oppose, or have
no comment on the preferred
alternative?
These final two criteria, which are
determined after the proposed plan,
are called "modifying criteria"
because new information or com-
ments from the State or the commu-
nity may modify the preferred
alternative or lead to another re-
sponse action being considered.
Then the alternatives are compared
against each other to identify the
most effective remedy.
The public has the opportunity
to review the RI and FS reports.
These reports are placed in the site
information repository, which is
usually located at a local library.
RI/FS Accomplishments
The Superfund Amendments
and Reauthorization Act (SARA) set
mandatory deadlines for the com-
mencement of RI/FSs: by October
1989, EPA had to have started at
least 275 RI/FSs. EPA more than
met this ambitious goal as the
mandated number of RI/FSs were
underway 3 months ahead of the
deadline. By the end of FY90, EPA
had started RI/FSs at more than
1,000 sites and completed RI/FSs at
more than 600 sites. Figure 7 shows
the trend in RI/FS starts over the
past 10 years.
Study.AtStaufferpHernical
|pl^4iyideqWe, plea^^
*~^~' "rtHrable;unjtsr& • (^.\,
^
"*d^^p/alt^ra^yefe(selepteUm separate F§ reports.-'' "
':
£jau^e)^EKiE^;^
joumi wkte/prhedia1ipnfwere .developedin'the'
gra^lsea^rfih^resjalts 6f the.-M:; Jj;'teke^p/actionXusedf©Y'dpm^arativ^ •. •;'-
J^p^gsW-ICeveryPiffe^r^'use' ilie'preseh^grpund wAter.l^eafment.systems'S);' ' / •
J|nPdi^the;present ^tep'tp'inUude/kdilitipnal^tr^action >ybils!ofjfsite5, and //
Figure 7
First RI/FS Starts
S
-------
I Remedial Activity
The Stauffer Chemical site
illustrates the complexity of the RI/
FS process. Several initiatives,
however, are underway to streamline
and expedite the RI/FS process.
EPA is limiting the number of
remedial alternatives considered in
the RI/FS to those with clear poten-
tial effectiveness. This will reduce
resources spent on evaluating
alternatives that are impracticable.
In addition, EPA is in the process of
developing prototype RI/FSs and
remedy-selection models for site
situations that occur frequently, such
as municipal landfills, polychlori-
nated biphenyls (PCB) sites, and
wood-treating facilities. Such
prototypes will be used as a starting
point for planning and conducting
studies. RPMs can start with the
prototype and adapt it to the specif-
ics of their site.
Deciding Upon A Course
Of Action
Once the alternatives for
cleanup at a site have been evaluated
and a preferred alternative has been
decided, EPA formally requests
comment from the public by pre-
senting this information in the
Proposed Plan. The Proposed Plan
summarizes the alternatives ana-
lyzed in the detailed analysis of the
FS, the preferred remedy and the
rationale for that preference, any
proposed waivers to cleanup stan-
dards, and the position of the
support agency (e.g., the State) on
the Proposed Plan and preferred
alternative.
In the Stauffer Chemical Pro-
posed Plan, EPA documented the
analysis of the four alternatives
against the nine evaluation criteria
and against each other. EPA con-
cluded that Alternative #3—a
modified treatment system—passed
the first two criteria and provided
the best balance among the remain-
ing criteria, compared to the other
alternatives.
The public is given the opportu-
nity for a public meeting to discuss
issues related to the site and to
submit oral and written comments to
EPA during the 30-day public
comment period. Following receipt
of public comments and any final
comments from the support agency,
the remedial action is selected and
the rationale is documented in the
Record of Decision (ROD). The
ROD details the remedial action
plan for a site or operable unit,
certifies that the remedy selection
process followed the requirements in
CERCLA and the National Contin-
gency Plan (NCP), discusses the
technical details of the remedy, and
provides the public with a consoli-
dated source of information about
the site. Once the Regional Admin-
istrator or the Assistant Administra-
tor of the Office of Solid Waste and
Emergency Response signs the
ROD, it is released for informational
purposes and placed in the adminis-
trative record for the site. More than
700 RODs have been signed since
the program began. Figure 8 shows
the number of RODs that have been
signed since FY81.
The ROD has become much
more valuable than simply docu-
menting the remedy selected at one
site. It is a record of what to do in a
given set of conditions. EPA has
developed a detailed data base of
RODs, called the Records of Deci-
sion System (RODS). RODS serves
as an information base for similar
site conditions and to promote
national consistency among RODs.
Figure 8
RODs Signed
8001
.
CO
w
Q
o
DC
0)
I
Z
§
1
3
O
600-
400-
200-
l
1
1981 1982 1983 1984 1985 1986 1987 1988 1989
Fiscal Year
18
1990
-------
Remedial Activity
Designing And Constructing
The Cleanup
Once the course of action has
been selected and approved, it is
time to design the remedial action
and carry it out. These are the last
phases of the remedial process:
remedial design (RD), remedial
action (RA), and operation and
maintenance (O&M). Unlike other
EPA programs which regulate
activities of the private sector, here
EPA actually manages the construc-
tion projects, designing the selected
remedy and implementing that
design.
RD is an engineering phase in
which technical drawings and
specifications are developed for the
subsequent RA, based on the
selected remedy documented in the
ROD. EPA assigns RD and RA
work to either the Alternative
Remedial Contract Strategy (ARCS)
contractors, the U.S. Corps of
Engineers, or the U.S. Bureau of
Reclamation, depending on the type
of remedy and the estimated cost of
the project. States and responsible
parties continue to manage the design
and construction of those Superfund
actions for which they have lead
responsibility. EPA RPMs provide
environmental oversight.
Remedial action projects may
appear to be like any other major
construction project, but in fact, the
presence of hazardous substances at
the site demands specially trained
engineers, scientists, and other
personnel; complex treatment equip-
ment; and special construction
planning and health and safety
procedures. In fact, a crucial element
of the RD/RA phase is the develop-
ment and implementation of the Site
Safety and Contingency Plans to
protect on-site personnel and sur-
rounding communities from the
physical, chemical, and/or biological
hazards of the site. These plans
include information on chemicals
present, equipment being used,
precautions to be taken, and steps to
take in the event of an emergency
situation at the site, including decon-
tamination procedures. Remedial
action projects also differ from the
usual construction project in that the
large volume of wastes to be treated
at many sites extends the RA
performance period over several
years and results in costs of tens of
millions of dollars.
After the RPM certifies that the
remedial action is complete and the
remedy is operational and func-
tional, the O&M phase begins.
O&M activities include ground
water and air monitoring, inspection
and maintenance of the treatment
equipment remaining on site, and
maintenance of any security mea-
sures such as signs and fencing. The
State or responsible party usually
assumes responsibility for these
activities, while EPA is responsible
for oversight to ensure the site is
maintained and remains safe.
Remedial Action
Accomplishments
SARA set ambitious goals for
beginning remedial actions at
Superfund sites: by October 1989,
the program had to have started RAs
at 175 sites, and by 1991, another
200 RAs must be started. EPA met
the goal for RA starts in 1989.
Figure 9 shows the trend of RD and
RA starts over the past 10 years.
EPA has made remedial action a
top priority and has taken several
steps for continuous improvement in
the pace and quality of RAs at
Superfund sites. By streamlining the
RI/FS and remedy selection pro-
cesses—through the use of prototype
RI/FS and remedy selection models,
an up-to-date ROD data base,
technical support from Headquar-
ters, and a peer review process—
today there are more sites in the
construction pipeline than ever
before. To address SARA mandates
for permanent remedies and the use
of alternative technologies where
possible, EPA has set up technical
19
-------
Remedial Activity
Figure 9
RD and RA Starts
800-1
600-
400
200
Remedial Designs
Remedial Actions
19B1
1982
1983
1984
1985 1986
Fiscal Year
1987
1988
1989
1990
r Use Of Technologies At French Limited Site
Innovative technologies are being moved out of the laboratories and into the field,
as illustrated by the remedial alternative selected for the French Limited site in
Crosby, Texas. More than 300,000 cubic yards of industrial wastes from local
petrochemical companies were deposited in an unlined pit at this site. Sludge and
soil from the waste pit were contaminated with PCBs, organics, and metals. A
removal action was conducted at the site in 1982 to contain the wastes and to
eliminate the immediate threats. The potentially responsible parties (PRPs) for the
site then funded and prepared an RI/FS. In deciding among the various alterna-
tives for remedial action at the site, EPA had to choose one that provided the best
-balance among the nine evaluation criteria. In addition, EPA gave serious
consideration to alternatives that met the preferences outlined in SARA: cleanup
alternatives that foster recycling or treatment of waste rather than land disposal;
and remedies that employ treatment technologies that permanently and signifi-
cantly reduce the threats posed by the waste.
EPA concluded that a new treatment technology called bioremediation best met all
of the above criteria. Bioremediation uses micro-organisms to detoxify organic
matter. As a condition to selecting the remedy, EPA required the PRPs to conduct
a pilot study at the site before applying this treatment on the entire site. The pilot
Study had to prove that bioremediation was at least as effective as the other
alternatives at the site (mainly, incineration) and did not pose additional signifi-
cant threats during the process. The pilot study, which was conducted on a Eaff-
-acre section of the site, was very successful, reducing the threats posed by the
waste while posing no significant health threats during treatment. In addition to
being an effective remedy, bioremediation was supported by the State and
community and was half as costly as incineration. The site is presently in the RD
phase, with the RA anticipated to begin in 1991. Almost 50 percent of the
treatment remedies approved in RODs over the last 2 years involve innovative
technologies, and that percentage is expected to continue to rise in the coming
years.
expert support systems and technol-
ogy evaluation programs to ensure
that existing knowledge and creative
ideas are being shared around the
country.
New Remedial Program
Initiatives
The remedial program is now an
established, action-oriented program
for identifying and cleaning up the
highest priority sites. The main
principles driving the program today
are:
• Address worst sites/worst
problems first. After abating
immediate threats, EPA will
initiate the earliest remedial
work to address the highest
priority problems (e.g., immi-
nent threat to human health,
highly toxic, highly mobile
contaminants). In many cases,
EPA is taking action in deliber-
ate stages that will result in
continuous improvements until
the site is finally cleaned up to
human health and environ-
mental standards. This may
20
-------
Remedial Activity
U-—-- -^nHlM^
include dividing the site into
operable units so that immedi-
ate attention is given to the
highest priority areas at a site.
Depending on site conditions,
EPA will take actions to
initially prevent exposure and
control risk; further actions will
be taken to reduce or eliminate
the risk. EPA is making sites
"cleaner"—while ensuring that
the stages of site cleanup are
consistent with the final
remedy—at as many NPL sites
as soon as possible.
Monitor and maintain sites.
In addition to quick action at a
site, EPA will monitor and
maintain sites over the long-
term to ensure that the remedy
at each site is fully protective
of human health and the
environment. As part of the
effort to monitor site condi-
tions, EPA will conduct, at
least every 5 years after the
initiation of the response
action, a review of all sites
where hazardous substances
remain on site. EPA also will
maintain the effectiveness of
the remedy over the long-term
by promptly correcting any
problems that are identified.
EPA will report annually to
Congress the results of all 5-
year reviews.
• Emphasize permanent
remedies using innovative
technologies. The ultimate
success of the Superfund
program depends on the
selection of remedies that
reduce risks to human health
and the environment in the
short term, and eliminate the
risks in the long term. This
initiative involves seeking
alternative technologies to land
disposal, developing new
technologies for more effective
cleanup, and ensuring that
these technologies provide
permanent protection to the
extent possible. SARA re-
quires that EPA give strong
preference to such remedies in
cleaning up Superfund sites.
EPA has been successful in creating
an environment conducive to
providing such remedies. This has
involved reducing regulatory and
policy barriers to the use of treat-
ment technologies and providing
extensive technical assistance,
expert advice, and information
transfer to make the best use of the
information that is available now
and that is under development. EPA
is aggressively supporting the
research, development, demonstra-
tion, and evaluation of new treat-
ment technologies to provide state-
of-the-art protection at Superfund
sites.
EPA has made great strides in
advancing the pace and quality of
long-term cleanup at Superfund sites
since the response to hazardous
chemicals found at Love Canal, New
York. The future of hazardous
waste cleanup is a challenge that can
and will be met. The Superfund
program has built up a sizeable
reservoir of knowledge in its first 10
years. The remedial program is in
place and information on effective
remedies is being developed and
shared throughout the program.
Cleanup activity at NPL sites is at
every stage of the remedial "pipe-
line"—sites that are in the Superfund
study and cleanup process. The
program will continue to grow and
address site problems through
aggressive goals, effective commu-
nication, and shared responsibility.
21
-------
The Enforcement Program
One of Superfund's major goals
is to have responsible parties pay for
and conduct cleanups at abandoned
or uncontrolled hazardous waste
sites. The foundation of Super-
fund's enforcement program is the
Comprehensive Environmental
Response, Compensation, and
Liability Act's (CERCLA) strict,
joint and several liability standard.
Under this standard, each poten-
tially responsible party (PRP)—
those owners and operators, waste
generators, and transporters at a
site—may be fully liable for all site
cleanup costs, regardless of waste
share or fault.
* In getting responsible parties to
r pay for or conduct site cleanups,
* EPA uses three, broad enforce-
"" ment'authorities to:
in Figure 10). PRPs now conduct
more than 60 percent of Superfund
remedial actions.
enforcement tools and reach settle-
ment agreements with responsible
parties.
One Superfund Program—Enforcement First.
EPA can negotiate settlements
with responsible parties to have
them conduct or pay for site clean-
ups. If negotiations fail, EPA issues
orders to responsible parties to
compel site cleanup. EPA also can
use Trust Fund monies to cover
cleanup costs and attempt to recover
the costs later through litigation. To
conserve Trust Fund dollars for
"orphan" sites, those where no
liable, financially-viable PRPs exist,
EPA's top priority is to use all its
The Enforcement Process
The enforcement process begins
immediately after a site is proposed
for listing on the National Priorities
List (NPL) (see Figure 11). At the
start of the NPL listing process, EPA
begins looking for PRPs who may
be liable for contamination at a site.
These PRP identification activities
are known as a PRP search. When
EPA has enough information to
identify a party as potentially
Reach settlements
Issue orders
Recover costs.
Figure 10
Total Value and Number of PRP Settlements
When CERCLA was reauthor-
ized and amended by the Superfund
Amendments and Reauthorization
Act (SARA) in 1986, Congress
reinforced and significantly
strengthened the law's enforcement
provisions. SARA provided en-
forcement "tools" to facilitate
settlement negotiations, and en-
hanced the enforcement measures
available to EPA in the event that
responsible parties do not settle. In
addition, the Superfund Manage-
ment Review established the "One
Superfund Program—Enforcement
First" concept to encourage or
compel responsible party cleanups
rather than using the Trust Fund, and
to integrate all EPA response and
enforcement activities. The result
has been a seven-fold increase, over
the last 4 years, in the total value of
settlements to $3.7 billion (as shown
4000.
I
c
o
EC
Q.
II
S. i
£ =
0
U
•D
S,
1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990
Fiscal Year and Cumulative Number of Settlements
22
-------
The Enforcement Program
Figure 11
Basic Enforcement Process
RI/FS Negotiations
with a 60-90 Day
Response Moratorium
RD/RA Negotiations
with a 60-120 Day
Response Moratorium
I \ Initfate
', /Other
Enforcement
Options •"
Refer Section 105/107 Case to Department of Justice
Seek Treble Damages
Use Fund to Clean Up Site and Refer Section 107 Case
responsible for the site, EPA issues a
general notice letter to each PRP
notifying them of their potential
liability. As soon as PRPs are
identified, EPA begins exchanging
information with them concerning
site conditions, PRP connections to
the site, and other potentially
responsible parties.
Based on information obtained
during the PRP search and informa-
tion exchange process, EPA also
may issue special notice letters to
PRPs. The special notice letter
begins a formal negotiation period
and establishes a moratorium (60-
90 days for RI/FS negotiations, 60-
120 days for RD/RA negotiations)
on certain response and enforcement
activities. If within 60 days, PRPs
make a "good-faith offer" to conduct
the response action, the moratorium
may be extended to provide addi-
tional time for reaching a final
settlement. An administrative
~T;f '^"js • "*'''• - -••f%° f• „- V" ^ u - \ sf ? .|J*?' n^u'^s"/^-C;*''-' fJ 't",!,*'^)- ^
s^i^^;^>i'^;?/.l4-.-^i^/s:///r|i:f#;;r';:f;*;.,;/, -/;/*/<'"•''- ^'.; *?/"i"-'//'*v--:-/* •*
[Ii^^*^£p>^jll|l%i^2i?H?A^?^-ri:)^y S^?111'%"P^y^1^t^ot-*?.'sqy*.tp;;; /. ,
l-^^^aSflHt^-rffetsAo ajBRP's/pbfigation to pay.Xespoiise.eps&dlready
additional response; acfiyities beydndstho.se .spefciiied in the ROD I
;i-s4fij -«t- t'frjZf ltl~-' <':'f- .;?'..«•>/#-.• I :-., ..s ,;,r :- :. ?,i ;>. .-,:,. .
f^^^*i:C^JSUIUiniS|SCTt][einents:-;EP^*rtiayr enter into de miriiinis s'ettlefrients/:''
^*^here?the€selflement .inciudes sonly a jiwior^orttoh* of .the iesfporfee costs,-:-
sursri ^W^^^s.^VJ?*: _..5_i Aa.±r ? _ - '*'/..»'"nifip*Iv^c? MR'AIJc arf tin*--' ' '-
23
-------
The Enforcement Program
record for a site, which includes all
documentation relating to the
selected remedy, is usually estab-
lished as soon as the site is discov-
ered. The administrative record is
the basis for any judicial review of a
settlement or the selected remedy by
the court.
Settlement agreements may be
reached to conduct a remedial
investigation/feasibility study (RI/
FS) or a remedial design/remedial
action (RD/RA). EPA has a variety
of enforcement tools provided by
SARA to encourage PRPs to settle
(see box on previous page). If
PRPs do not agree to conduct the RI/
FS, they may settle at a later date to
conduct the RD/RA. However,
PRPs who are actively involved in
site work from the time they receive
a general notice letter, and who
conduct the feasibility study, can
have more input on the remedy that
is selected. Figure 12 summarizes
PRP involvement in response actions
since Superfund's inception.
A settlement agreement to
conduct an RI/FS is usually formal-
ized in an administrative order on
consent (AOC). AOCs are issued
under EPA's administrative authority
and legally bind both EPA and the
settling PRPs. Although AOCs are
not lodged in court, the Department
of Justice (DOJ) may review certain
RI/FS settlements. RD/RA settle-
ments, however, must be lodged in
court by DOJ, in the form of a
consent decree. For all settlements,
DOJ represents EPA in actions
brought by responsible parties.
If PRPs do not settle, EPA can
either issue orders to force liable,
financially viable PRPs to conduct
the response action, or spend Trust
Fund monies and recover the costs
from the PRPs later. For RD/RAs,
EPA routinely issues unilateral
administrative orders (UAOs) to
force non-settling PRPs to imple-
ment the remedy themselves. UAOs
are legally binding and do not
require EPA to sue PRPs in court to
become effective. In addition,
UAOs do not provide PRPs some of
the advantages of settlements, such
as protection from other PRPs or
other third parties seeking contribu-
tion for response costs. Non-
compliance with a UAO can result
in civil penalties of $25,000 per day,
and if Trust Fund monies are spent,
EPA may seek triple the cost of the
response action (treble damages) in
cost recovery litigation. Finally, if
PRPs do not comply with a UAO,
EPA may sue in court and obtain a
court order forcing them to conduct
the response action and to reimburse
EPA for its oversight costs.
ouu -
c. Aftf\
g *HJU -
<
O
Ul
8. goo -
UJ «•>""
o>
DC
"o
c e\3\J -
3
2
_«
E 100 -
O
Figure 12
Trend in PRP-Financed Response Actions
1981
JKtofuui.iWjfcfc..-jJMt
,— - '
RI/FS
' RD
RA
tiLxmiMM^JtA^
*^
jj( t
^
/
/
/
A
/
^
XV
/
/
^
/
/
X
./?*
'Jf'^
1982 1983 1984 1985 1986 1987 1988 1989 1990
Fiscal Year
24
-------
The Enforcement Program
EPA also has the option to
spend Trust Fund monies to conduct
the cleanup, and then recover the
costs from the responsible parties.
Under CERCLA, any past and
present owner and operator at a site,
as well as waste generators and
transporters, can be held fully liable
by the courts for complete cleanup
costs. During a response action,
EPA develops a cost recovery case
and refers it to DOJ for litigation.
Since 1980, EPA has referred 391
civil cases seeking $644 million in
past costs to DOJ (see Figure 13).
Aggressive enforcement efforts
are necessary to the Superfund
program because the cost of clean-
ing up all the sites on the NPL far
exceeds the money available in the
Trust Fund. For its part, EPA has
developed critical guidance and
model administrative documents,
produced a draft cost recovery
regulation to expedite cases, and
hired 500 new personnel based on
recommendations in the 1989
Superfund Management Review to
push sites through to cleanup. With
the enforcement program's infra-
structure in place and the implemen-
tation of the "One Program—
Enforcement First" concept, the
involvement of PRPs in Superfund
cleanups will continue to grow.
Figure 13
Total Value and Number of
Section 107 Cost Recovery Referrals
in
•£ 300 -
S
o
•o
1
200-
100-
1980 1981 1982 1983 1984 1985 1986 1987 1988 1989
Fiscal Year and Cumulative Number of Settlements
1990
25
-------
Public Participation In Decisionmaking
Like every component of the
Superfund program, the community
relations initiative has grown and
matured since Superfund's inception
in 1980. From the beginning, EPA
recognized the importance of
community input and involvement in
the hazardous waste site cleanup
process. Agency staff at Headquar-
ters and in the field realized that the
most innovative cleanup technology
could not be considered successful if
f Superfund community relations
I activities are important to:
; • Promote two-way
I communication
I
I • Provide input to technical
[ decisions
1 : • .. •].
- • Discover useful site
i information
• Focus and resolve conflict.
I
it was not accepted by the "affected
public"— the people who live and
work near the hazardous waste sites.
In the early days of the program,
community relations activities
generally occurred
on an informal,
site-specific basis.
There were no
required activities;
specific communi- ^^^^^^^^
cation and infor-
mation needs of the
interested citizens determined each
site's public participation initiative.
As the program evolved, the Agency
formulated policy statements and
developed program guidance. The
1982 National Oil and Hazardous
Substances Pollution Contingency
Plan (NCP) contained requirements
for community relations at all
remedial sites and for removals
lasting more than 120 days. In
1986, the Superfund Amendments
and Reauthorization Act (SARA)
added legislative requirements and
in 1989, the Superfund Management
Review made recommendations to
further improve the community
relations program. Throughout the
years, one aspect of the program has
been maintained—EPA still con-
ducts community relations activities
on a site-specific basis. Although
today's program has many required
activities, each one is tailored to the
specific issues of importance to the
public, the level of concern, the
history of public involvement, and
the economic and social structure of
the community.
Achieving Public
Participation
Community relations activities
have occurred at every site at which
an RI/FS has been started and at all
removal sites where time has
allowed. Community relations
efforts promote two-way communi-
cation among members of the
public, State and local officials,
other Federal agencies such as the
Community relations efforts promote
two-way communication.
U.S. Corps of Engineers, the U.S.
Coast Guard, and the Department of
Defense, and EPA.
The community relations
program encourages communication
with affected citizens and participa-
tion in decisionmaking. It has three
main objectives:
• Give the public the opportunity
to comment on and provide
input to technical decisions.
26
-------
Public Participation In Decisionmaking
• Inform the public of planned or
ongoing actions and keep them
apprised of the nature of the
environmental problem, the
threats it may pose, the re-
sponses under consideration,
and the progress being made.
• Focus and resolve conflict.
Conflict may be unavoidable in
some circumstances, but it can
be constructive if it brings into
the open alternative viewpoints.
Every phase of the technical
schedule for site cleanup has corre-
sponding community relations
requirements. For a remedial site, a
Community Relations Plan (CRP)
must be developed before RI/FS
field work begins. The CRP is the
"work plan" for community relations
activities that EPA will conduct
during the entire cleanup process. In
developing a CRP, Agency staff
members conduct interviews with
State and local officials and inter-
ested citizens. Through this one-on-
one interaction, EPA learns about
citizen concerns, site conditions, and
local history. This information is
used to formulate a schedule of
activities designed to keep citizens
apprised and to keep EPA aware of
community concerns. Typical
community relations activities
include public meetings, at which
EPA presents a summary of techni-
cal information regarding the site
and citizens can ask questions or
comment; small, informal public
availability sessions at which EPA
representatives make themselves
available to citizens; and develop-
ment of fact sheets, which the
Agency distributes periodically to
keep citizens up-to-date on site
activities.
Part of every CRP is the estab-
lishment of an information reposi-
tory. EPA is required to set up a file
of information related to the site in a
building accessible to citizens.
Usually housed in a library or town
hall, the repository contains reports,
studies, fact sheets, and other
documents containing information
about the site. EPA continually
updates the repository and must
ensure that the facility housing the
file has copying capabilities.
After the RI/FS is completed
and EPA has recommended a
preferred cleanup alternative, the
Agency sends to all interested
parties a Proposed Plan outlining the
cleanup technologies that were
studied and explaining why EPA
prefers one remedy over the others.
At this time, EPA also begins a
public comment period during which
citizens are encouraged to submit
comments regarding all alternatives.
Once the public comment period
ends, EPA develops a Responsive-
ness Summary, which contains EPA
responses to public comments. The
Responsiveness Summary becomes
part of the Record of Decision
(ROD), which provides official
documentation of the remedy chosen
for the site.
Community relations activities
occur at specific points in the
remedial process, as shown in Figure
14. In addition to meeting these
Federal requirements, EPA makes
every attempt to ensure that commu-
nity relations is a continuing activity.
designed to meet the specific needs
of the community.
What EPA Has Learned
Superfund participants at the
Federal, State, and local levels
acknowledge the importance of
public participation in the Superfund
program. Because it is such an
integral part of all cleanup opera-
tions, EPA is constantly striving to
improve its communications with
the public. Agency experience over
the past 10 years has yielded general
conclusions about the nature of
public involvement in hazardous
waste issues, and, in turn, about the
most helpful approaches to public
participation. EPA has learned, for
example, that its decisionmaking
ability is enhanced by actively
soliciting comments and information
from the public. In addition, experi-
ence has shown that the earlier EPA
establishes a working relationship
with citizens near a site, the greater
chance there is for trust and confi-
dence to develop between the
parties. EPA also has found that
communities often are able to
provide valuable information on
local history, citizen involvement,
and site conditions. Establishing a
dialogue between Agency staff and
citizens, therefore, allows both the
public and EPA access to important
information. This dialogue can help
identify citizen concerns about the
site, enabling EPA to be most
responsive to community needs.
By planning at the outset for a
high level of citizen involvement,
EPA has usually been able to avoid
the delays in cleanup which might
otherwise arise from uninvolved and
disaffected citizens. Consequently,
27
-------
Public Participation In Decisionmaking
Figure 14
Overview of EPA Community Relations Requirements
Decision Point
(Technical Process)
EPA Community
Relations Requirements
Opportunities For
Participation
NPL Listing
Publish the proposed additions to the NPL
in the Federal Register: solicit comments
through a public comment period
Submit comments in support of or
opposition to the site being listed on the
NPL
RI/FS and
Administrative Report
Develop Community Relations Plan (CRP)
Establish information repository and
administrative record
Announce and describe the TAG Program
Participate in on-scene interviews; submit
names for mailing list
Periodically review site-related information
Assess community need for TAG; if
appropriate, submit application
Proposed Plan
Notify public of Proposed Plan; make plan
available in information repository and
administrative record
Provide opportunity for public meeting
Conduct a minimum 30-day public
comment period
Review alternatives
Request meeting; gain further insight into
cleanup alternatives
Submit written or oral comments on the
alternatives
ROD
Prepare Responsiveness Summary; make
it and ROD available in information
repository and administrative record
Review and comment on EPA decision
document
RD/RA
Revise CRP, if necessary
Make remedial design available in
information repository and administrative
record
Prepare fact sheet on remedial design
Provide opportunity for public meeting
Participate in on-scene interviews
Review remedial design
Read fact sheet
Request meeting; gain further insight into
design
NPL Deletion
Place copies of information supporting the
proposed deletion in the information
repository
Publish a notice of intent to delete in the
Federal Register and solicit comments
through a minimum 30-day public
comment period
Respond to comments and include
responses in the final deletion package in
the information repository
Review information regarding proposed
deletion
Submit comments in support of or
opposition to the site being deleted
Review the final deletion package
28
-------
Public Participation In Decisionmaking
Agency staff members are committ-
ed to listening to citizen concerns
and fully involving the public in the
decisionmaking process "early, often
and always."
The Technical Assistance
Grant (TAG) Program
One of the most significant
accomplishments of the Superfund
community relations program is the
awarding of technical assistance
grants or TAGs. Established by
Congress in 1986, the TAG program
helps ensure that affected individu-
als are well informed about the
conditions and activities at
Superfund sites in their communi-
ties. The program provides groups
with grants to hire independent
technical advisors who can help
them understand technical informa-
tion related to cleaning up a site.
One grant of up to $50,000 is
available for each site as long as the
site is listed or has been proposed
for listing on the NPL, and EPA has
begun its response action at the site.
If the site is a complex one, it is
possible to receive additional
*ac. •*
Kr-,-"
funding. To date, EPA has
awarded 40 grants across all
ten EPA Regions, as shown
in Figure 15.
Groups eligible to
receive TAGs are groups of
individuals who live near the
site and whose health,
economic well-being, or
enjoyment of the environ-
ment is directly threatened.
Such groups could be
existing citizens' associa-
tions, environmental or
health advocacy or similar
organizations, or coalitions of such
groups formed to deal with commu-
nity concerns about a hazardous
waste site and its impact on the
surrounding area.
In general, grant funds may be
used to hire technical advisors to
increase citizen understanding of
existing information about the site,
or that is developed during the
Superfund cleanup process. Grant
monies are often used to pay techni-
cal advisors to review site-related
documents, meet with the recipient
Figure 15
Technical Assistance Grants
Accomplishments
,
at'staje of cleanup ,
VJhs *• %h,ere TAGxjoulcf be useful -
65|;' < 1TA<3 applications .received,
i^U '•;!!••• 'H^.ii?'^ H-;
-' '
group to explain technical informa-
tion and interpret technical informa-
tion for the community.
EPA has Community Relations
Coordinators and TAG Coordinators
at Headquarters and in each EPA
Region. The addresses and tele-
phone numbers of Headquarters and
Regional Offices are presented at the
end of this document.
29
-------
Roles Of States And Indian Tribes
States continue to take lead
responsibility for Superfund re-
sponse at many sites, and that
number is expected to increase
significantly as individual State
hazardous waste programs mature.
For example, States have led nearly
300 remedial investigation/feasibil-
ity studies (RI/FSs) and more than
80 remedial actions (RAs) since the
program's inception, with the most
dramatic increase in Superfund
activity happening during the last 4
years.
States and political subdivisions
(such as county governments) with
the necessary technical and manage-
ment expertise are authorized to lead
cleanup efforts. The Comprehensive
Environmental Response, Compen-
sation, and Liability Act (CERCLA)
also requires EPA to coordinate with
States when the Federal government
leads site response.
- State and Indian Tribal involve-
ment in the Superfund program is
i. based on:
• Requirements found in the
Superfund Amendments and
Reauthorization Act (SARA),
• Procedures outlined in the
National Oil and Hazardous
Substances Pollution Contin-
gency Plan (NCP) and
; Superfund Administrative
Regulation, and
* Formal agreements between
States, political subdivisions,
or Indian Tribes and EPA.
In the earlier days of the Super-
fund program, EPA focused on
involving States in individual
remedial activities, while the
Agency developed a better under-
standing of the requirements for
effective response. EPA relied on
comprehensive guidance for State
participation because the original
Superfund law provided few proce-
dures for getting States involved.
The enactment of SARA strength-
ened and broadened State involve-
ment in Superfund by specifying the
points at which State participation is
required. SARA outlines minimum
requirements for involving States in
virtually every phase of Superfund
decisionmaking. As a result, States
can participate in enforcement,
removal actions, site assessment,
and remedial activities. SARA also
enables EPA to help States increase
their role in site-specific response by
funding their non-site-specific,
general Superfund programs.
SARA extends this EPA/State
interaction to Indian Tribes, as well.
EPA must treat Indian Tribal
governments substantially the same
as States, which may either lead a
response or provide support when
EPA leads the activities. To be
considered the same as States, an
Indian Tribe must be Federally
recognized by the Bureau of Indian
Affairs, have jurisdiction over a site
in EPA's data base of hazardous
waste site information or a site on
the National Priorities List (NPL),
and have a Tribal governing body
that is promoting health, safety, and
welfare of the affected population.
Local governments also play an
important role during a Superfund
cleanup. Localities may lead a
response action and often provide
important public safety measures
during emergencies, for which they
may receive some financial assis-
tance under the Local Governments
Reimbursement (LGR) program.
The LGR program is intended to
ease the financial burden on local
governments from conducting
temporary emergency measures in
response to a hazardous substance
threat. The program offers assis-
tance of up to $25,000 per response
directly to local governments.
Statutory And Regulatory
Framework
CERCLA authorizes the Federal
government to lead hazardous waste
response activities at a site, or to
transfer the necessary funds and
management responsibility to a State
(State-lead), a political subdivisipn
of a State, or a Federally recognized
Indian Tribe. Regardless of which
level of government leads a re-
sponse, the State must make certain
assurances to EPA. As part of these
assurances, the State must pay part
of the cleanup costs. If the site was
privately operated at the time of the
hazardous substance release, the
State must pay 10 percent of the
costs of the actual cleanup. If the
State or a locality operated the site
when hazardous substances were
disposed there, it must pay 50
percent or more of all Federal
response costs.
In addition to helping defray
some of the costs, a State must also
ensure the availability of a disposal
facility for hazardous materials
removed from a site during cleanup,
as well as ensure its capacity to
adequately handle all hazardous
wastes generated within the State
over 20 years, starting from 1989.
Operation and maintenance of the
selected remedy once the cleanup is
completed and is proven to be
running smoothly also is the respon-
sibility of the State as part of its
assurances to the EPA.
The NCP (Subpart F) clarifies
how EPA will achieve substantial
and meaningful involvement by each
State and Indian Tribe. The
Superfund Administrative Regula-
tion (40 CFR Part 35 Subpart O)
defines how EPA can transfer funds
for site response to State, political
subdivision, and Indian Tribal
Superfund programs to support the
development of their programs'
30
-------
Roles Of States And Indian Tribes
goals and maintain their effective-
ness to respond to hazardous waste
threats.
Promoting State And Indian
Tribal Involvement
EPA has developed four ways to
involve States, Indian Tribes, and
political subdivisions in Superfund:
• Cooperative Agreements:
Cooperative Agreements
transfer funds from EPA to
States, political subdivisions, or
Indian Tribes to lead site-
specific responses or to cover
the costs of their participation
in Federal-lead or other
CERCLA activities. A Coop-
erative Agreement also is the
legally binding document to
obtain required State cost
shares and CERCLA section
104 assurances when a State or
Indian Tribe leads a remedial
action. Under a Cooperative
Agreement, the State, political
subdivision, or Indian Tribe can
lead a response at a site or
several response actions at one
or more sites.
• Superfund State Contracts
(SSCs): SSCs are joint, legally
binding agreements between a
State or Indian Tribe and EPA
that assure the transfer of cost-
sharing funds when EPA is
leading a Superfund response
action. SSCs document that
States or Indian Tribes have
made all required assurances
under CERCLA, as amended.
They also can be used to
specify required State involve-
ment during a political subdivi-
sion-lead response.
• Core Program Cooperative
Agreements: EPA created
Core Program Cooperative
Agreements to provide general
Superfund program support
funds to States and Indian
Tribes. Core Program funding
defrays the cost of essential
State and Indian Tribe activities
that cannot be accounted for on
a site-specific basis, but are
essential to an active role in
CERCLA implementation. For
example, States and Indian
Tribes have used Core Program
Cooperative Agreements to pay
for administrative and clerical
salaries, computer resources,
program management,
recordkeeping, and training.
• Superfund Memoranda of
Agreement (SMOAs): EPA
developed SMOAs to define
the working Superfund partner-
ship between EPA and a State
or Indian Tribe. A SMOA is an
optional document that speci-
fies the procedures that EPA
and a State or Indian Tribe will
use to implement CERCLA and
theNCP. These procedures
then serve as the basis for site-
specific Cooperative Agree-
ments or SSCs.
State And Indian Tribal
Accomplishments
The number of State-lead
activities is greatest in the site
assessment program. States have
identified more than 32 percent of
the sites that are currently listed in
EPA's inventory of hazardous waste
sites. To date, States have assumed
responsibility for approximately
20,500 preliminary assessments
(PAs), or nearly 60 percent of the
national total. They have completed
19,500, or more than 58 percent of
all PAs conducted within the
Superfund program. States also
have completed more than 4,500 site
investigations (Sis) and Hazard
Ranking System calculations, 32
percent of the total number of Sis
that have been completed nation-
wide. Two Indian Tribal govern-
ments also have been awarded
Cooperative Agreements to conduct
site assessment activities.
States have made an equally
significant contribution to remedial
activities at hazardous waste sites
(see Figures 16 through 18). Since
1980, States have completed 139 RI/
FSs, 51 remedial designs (RDs), and
Each State and Indian
Tribe may determine the
role it will take in
Superfund.
27 RAs. This represents 16 percent,
14 percent, and 15 percent of total
nationwide RI/FS, RD, and RA
completions, respectively. In
addition, the number of ongoing
activities led by States has grown
steadily over time. This increase
suggests a strong State commitment
toward long-term cleanup activities.
Four Indian Tribes also have been
awarded Cooperative Agreements to
conduct support agency activities
during Federal-lead remedial
response activities.
Core Program funds have also
made a critical difference in increas-
ing State and Indian Tribal Super-
fund capabilities. The Core Program
began in FY87 with three States
participating in pilot activities.
Today, all States, Territories, and
Federally recognized Indian Tribes
are eligible to participate, and 44
States, the Territory of Puerto Rico,
and three Indian Tribal governments
are active in the program. Through
the Core Program, each State,
Territory, and Indian Tribal govern-
ment has the opportunity to deter-
mine the long-term role it will take
in Superfund.
31
-------
Roles Of States And Indian Tribes
State Superfund Program Success Stories:
"T: • , K ":•'•< , :; •>• , ]
Core Program Funds Make A Difference...
' .'•'! , " - jl-: - ' , ' - " j
Mississippi's State Superfund Program has come a long
way since 1987. From the passage of CERCLA until mid-
1987, Mississippi had only four full-time staff and one
part-lime supervisor. Response operations were limited.
In 1988, however, the State entered into a Core Program
Cooperative Agreement with EPA which allowed Missis-
sippi to expand its program and, therefore, its effect on
cleaning up hazardous waste sites. This expansion, which
continued with funding provided by Cooperative Agree-
ments with the EPA in 1989 and 1990, included increasing
professional staff dedicated to Superfund response four-
fold, and subsequent participation in site assessment
activities. In addition, the State's ability to take aggres-
sive enforcement actions'against individuals or firms
responsible for contributing to abandoned hazardous waste
sites improved.
Mississippi is currently pursuing enforcement activities
under administrative orders at 100 sites, representing
nearly one-third of the Mississippi sites listed in the
CERCLA Information System (CERCLIS). The State has
developed an enforcement action guidance document
consistent with the NCP, entered into a SMOA with EPA,
signed a Cooperative Agreement to provide funds to
review technical documents and actions at its two NPL
sites, entered into the nation's first SMOA with the
Department of Defense (DOD) to oversee response actions
at abandoned DOD facilities, and is in the final stages of
negotiating a similar SMOA with the Department of
Energy.
Political Subdivisions Can Play A Critical Role...
South Adams County, Colorado needed clean water. As
part of a remedial action, EPA planned to provide local
citizens with a permanent alternate water supply to take
the place of contaminated existing sources. Design and
construction of this were expected to take a substantial
period of time to complete, and EPA was unable to
provide an interim alternate water supply until the perma-
nent one was in place. As a result, South Adams County
offered to take the lead for the interim cleanup measures.
The County entered into a political subdivision-lead
Cooperative Agreement with EPA which provided an
interim water supply that included hooking up residences
and implementing otherIntenm measures toprotectthe
human health and the elwronrnenTTfiroiigfi its involve-
ment in the Cooperative Agreement, South Adams County
gained significant experience in site remediation activities
as well as in the whole Superfund process. The County
continued to play an active role in site actions throughout
the entire remedial action.
Figure 16
State-Lead Remedial Investigation/
Feasibility Study Starts
300
250
u>
•5 200
S
.a
I 150
100
I
50
7-
1980 1981 1982
1983 1984 1985 1986
Fiscal Year
1987 1988 1989 1990
Figure 17
State-Lead Remedial Design Starts
a
3
u>
"a
I
I
120
100
80
60
40
20
7
1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990
Fiscal Year
Figure 18
State-Lead Remedial Action Starts
E
o
100
80
60
40
20
1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990
Fiscal Year
32
-------
Management Infrastructure
KfftipIe| ''iSuperf6'tfd-b'rbgramv' 4* • &
"'' - '•' -TV/ *":*".' ." • " +'/">
l^^approaenes f&r'achie:^irig>",'-/" •-'/)
<*i&'Sfrt*rf;'_-:i -'/--i''*"*•'.'• - f"V -•?•-.
24&;;^Pgmepng(^dtactaAlpgy.y-:.i
v/»; ^dji&k-'^j&i
EPA spent most of the first
decade of Superfund getting its
house in order, and developing and
enhancing the organizational struc-
ture and management systems
necessary to get the job done, with
cleanup progress accelerating by the
end of the decade.
Judging the seriousness of
potential threats at each Superfund
site and determining the best solu-
tion is a complex task. It requires a
sophisticated infrastructure of
management systems and scientific
and technological expertise. One of
Superfund's most significant accom-
plishments during its first decade
has been the development of such a
network. EPA has developed and
continues to streamline management
procedures and policies for admini-
stering the Superfund program.
In addition, efforts by the
scientific and engineering commu-
nity to solve the unique problems
presented by Superfund sites have
resulted in the development of a
wide range of new techniques for
treating hazardous substances and a
greater understanding of their health
effects.
Building The Program
In 1980, the nation committed
itself to a major Federal effort to
tackle its hazardous waste problem.
From this mandate, EPA designed,
enacted, and put into place the
Superfund program—its contracting
mechanisms, management informa-
tion systems, accounting procedures,
scientific, legal and technical
protocols, and program planning and
evaluation measures. The early slow
pace of the program stemmed, in
part, from the difficulty of moving
ahead before program policies,
procedures, roles, and responsibili-
USEPA
COMBUSTION RESEARCH FACILITY
ties were clearly defined. Today, the
management foundation of
Superfund is solidly in place and is
continually being refined and
enhanced.
Further, the Agency coordinates
the efforts of EPA staff in its Wash-
ington, D.C., Headquarters, its front-
line staff in ten Regional offices
across the nation, State government
staff, contractors, and private parties
who assume responsibility for
cleanup. Comprehensive informa-
tion systems have been developed,
not only to manage the large sums of
money being spent and the efforts
underway at hundreds of projects
simultaneously, but also to exchange
state-of-the-art technical information
on chemicals, technologies, safety
procedures, and sources of assis-
tance. The Superfund program also
has initiated a new strategic plan-
ning system aimed at identifying and
prioritizing critical activities over a
5-year period. This system comple-
ments the Agency's overall planning
activities for achieving cross-
program integration and comprehen-
sive risk reduction.
Managing For Continual
Improvement
EPA has realized, however, that
its infrastructure must continue to
evolve, and has taken innovative
steps to improve its performance.
First, Total Quality Management
principles are now being applied in
all parts of the Superfund program to
clearly define program customers
and requirements, produce error-free
work, improve operations constantly
and forever, and effectively manage
the workload by preventing waste
and inefficiency. Another signifi-
cant step was completion of the
Agency's Superfund Management
Review in 1989. The Management
Review of the Superfund Program is
providing the strategy for a second
decade of increased program integ-
rity and a full "pipeline" of site
33
-------
Management Infrastructure
activity. This review provided more
than 50 recommendations for
addressing fundamental issues
facing the program:
• Reducing environmental risks
from a growing list of sites
that present new complexities
• Making defensible cleanup
decisions, sometimes without
complete knowledge of
environmental and health risks
• Maximizing the use of treat-
ment technologies, recogniz-
ing that many of these tech-
nologies are new and untested
in the field
• Making efficient use of
limited resources.
Today, EPA has completed nearly
all of the more than 120 manage-
ment improvement measures identi-
fied in this self-evaluation.
One of the most significant
accomplishments of the Superfund
Management Review is the develop-
ment of a Long-Term Contracting
Strategy for the Superfund program.
The Agency's purpose in developing
this strategy was to analyze the long-
term contracting needs of the
program, and design a portfolio of
Superfund contracts to meet those
needs over the next 10 years.
Completed in September of 1990,
the strategy will help integrate
enforcement and site cleanup
activities, enhance competition by
reducing the size of contracts and
creating more opportunities for
smaller businesses, and provide
greater management flexibility and
improved oversight and cost control.
Communicating Program
Results
Many have judged the success
of the Superfund program by the
number of sites removed from the
NPL. While that number reflects one
measure of progress, it does not
begin to tell the entire story. Success
for Superfund is more appropriately
measured in terms of the successive,
incremental cleanup steps that
quickly reduce threats to people and
the environment and ultimately
provide long-term protection.
Instead of concentrating on
continuous and complete cleanup of
a few major sites, the Agency will
now dedicate resources to ensure the
greatest degree of public safety at the
Developing The Science
Behind The Solutions
The Superfund program has
explored new frontiers in the applied
sciences. To address hazardous
substance problems, Superfund
response personnel must understand
how complex mixtures of chemicals
travel through the soil, ground
water, and the air. This has been a
long and complex task for environ-
mental scientists, requiring a combi-
nation of real world field sampling
results and theoretical models.
... dedicate resources to ensure the greatest degree
of public safety at the largest number of sites.
largest number of sites. The longer
process of total site cleanup on a
national scale will move forward
steadily at the same time as incre-
mental progress is being made at
sites. Deleting a site from the NPL
will become a distant goal, as EPA
focuses on the more meaningful task
of solving immediate problems that
affect human health and safety.
Superfund has made real envi-
ronmental gains and has developed a
new means of portraying progress.
These new measures, known as
environmental indicators, describe
tangible environmental improve-
ments in terms that are useful and
familiar. For example, progress in
making sites safer can be viewed in
terms of efforts to control immediate
threats (such as providing an alter-
nate water supply). Progress also can
be measured in terms of making sites
clean (such as reaching goals for
permanent site cleanup). A third way
to characterize Superfund progress is
EPA's efforts to bring technology to
bear on site problems. As shown in
Figure 19, on the following page, the
Superfund program is using technol-
ogy to remove contamination from
the environment.
34
EPA's knowledge of how contami-
nants enter and travel through
environmental media has increased
significantly as the Agency has
evaluated more and more sites for
possible Superfund response.
Of even greater complexity has
been the task of estimating the
degree to which human health is
endangered by Superfund sites.
Typically, people at risk because of
a waste site have been exposed to
very small quantities of hazardous
substances over a prolonged period,
and the health effects of these
substances usually do not surface
until long after the exposure has
taken place. During the first decade
of the Superfund program, EPA and
other Federal agencies, particularly
the Agency for Toxic Substances
and Disease Registry (ATSDR)
within the Department of Health and
Human Services, focused on assess-
ing risks at specific sites and refin-
ing the risk assessment process. As
a result of the 1986 amendments to
the Comprehensive Environmental
Response, Compensation, and
Liability Act (CERCLA), ATSDR
also began preparing toxicological
profiles for the most frequently
-------
Management Infrastructure
found substances at Superfund sites,
and completed health assessments
for all National Priorities List (NPL)
sites within 1 year of their inclusion
on the NPL.
Encouraging New
Technology For Risk
Reduction
The 1980 Superfund law did not
have specific provisions for research
and development of engineering
techniques and equipment for
handling, containing, treating, and
disposing of hazardous substances.
The Superfund Amendments and
Reauthorization Act (SARA)
required EPA to establish a formal
research and development program,
including demonstration programs
for technologies that offer alterna-
tives to conventional methods of
handling site cleanups, and favoring
methods that lead to the destruction
or recycling of wastes rather than
land disposal. SARA also called for
training programs for hazardous
substance response and research.
In 1986, EPA began the Super-
fund Innovative Technology Evalu-
ation (SITE) program to promote the
development and use of innovative
technologies to clean up Superfund
sites across the country. Now in its
fifth year, SITE is helping to provide
the treatment technologies necessary
to implement new Federal and State
cleanup standards aimed at perma-
nent remedies rather than quick
fixes. The SITE program is really
three related programs: the Demon-
stration Program, the Emerging
Technologies Program, and the
Measurement and Monitoring
Technologies Program.
To date, the major focus of the
SITE program has been on the
Demonstration Program, which is
designed to generate engineering
and cost data on selected, innovative
technologies. In this program,
Figure 19
Waste Removed From The Environment
Pathway
Volumes Addressed
Polluted Land Surface:
Soil 4,130,000 cubic yards
Solid Waste 5,270,000 cubic yards
Liquid Waste 1,000,000,000 gallons
Polluted
Ground Water: 3,880,000,000 gallons
Polluted
Surface Water: 104,000,000 gallons
technology developers are respon-
sible for demonstrating their innova-
tive systems at selected sites, while
EPA is responsible for sampling,
analyzing, and evaluating all test
results. The information gathered
during the demonstrations is used in
combination with other data as a
basis for selecting the most appro-
priate technologies for the cleanup
of Superfund sites. More than 52
developers are now active partici-
pants in the Demonstration Program
for field-scale technologies. They
represent a wide variety of innova-
tive technologies, from thermal
treatment and bioremediation to soil
washing, solvent extraction, and in-
situ stripping. Since the first dem-
onstration in 1987, EPA has con-
ducted 19 demonstrations.
The Emerging Technologies
Program provides 2-year funding to
developers of emerging technologies
to support bench-scale and pilot
testing of innovative treatment tech-
nologies. EPA has accepted a total
of 31 bench- and pilot-scale technolo-
gies to date. Laser technology is one
method being investigated for use in
reducing the toxicity of wastes at
Superfund sites.
Lastly, the Monitoring and Meas-
urement Technologies Program
supports the development and demon-
stration of innovative field-ready
technologies that detect, monitor, or
measure hazardous substances in the
air, surface water, soil, subsurface,
and in waste materials and biological
tissues. This program began in earnest
in 1990, and four demonstrations have
been completed. EPA continues to
seek new information on field methods
to measure and monitor contamination
and its effects on the environment.
35
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Future Directions And Challenges
Is the Superfund program
working? Yes. This complex and
challenging program is now up and
running.
During the last 10 years, EPA
has developed a program which has
brought this country to a new level
of understanding about hazardous
substances and how they can be
treated. The Superfund program is
comprehensive, yet flexible and
innovative. Its mission is both
immediate and long-range; its focus
is specific enough to handle individ-
ual site cleanups with precision, yet
broad enough to encourage advances
in a relatively new scientific and
technical field.
Superfund has resulted in
permanent solutions to major
hazardous waste problems already.
But that is not enough. After 10
years of experience, the most
important lesson that all Superfund
participants have learned is that the
program faces a workload stretching
well into the next century. The
hazardous waste problem in the
United States remains large, com-
plex, and long-term. The job ahead
is enormous. It will take technical
innovation and competence, man-
agement skill and creativity, and
old-fashioned dedication and hard
work to clean all the sites currently
known to present unacceptable risk.
And that number is growing, as new
sites continue to be discovered.
The Agency is looking beyond
the next 10 years to project a pro-
gram for the future—Superfund
2000. Superfund 2000 is a concept
for long-term program planning.
As part of this concept, EPA is
programs, are being assessed. In
keeping with the Agency-wide goal
of increasing multi-media enforce-
ment efforts by 25 percent, EPA is
examining the future role of respon-
sible parties and State and local
governments in the Superfund
program. All these studies and
activities will help ensure that an
integrated, pragmatic, and results-
oriented Superfund program will
continue to evolve.
The hazardous waste problem in the United States
remains large, complex, and long-term.
conducting studies of the possible
universe of sites to be cleaned up by
Superfund or other parties. An
outyear liability model will help the
Superfund program estimate pos-
sible future cleanup costs under
different scenarios. The Agency
also is looking at past remedy
selection decisions and evaluating
patterns that may indicate the future
success of various technologies.
Opportunities for greater program
integration, particularly between the
Superfund and Resource Conserva-
tion and Recovery Act (RCRA)
The Agency is proud of its hard-
won accomplishments in the Super-
fund program, and will continue to
use new management and techno-
logical approaches to accelerate the
pace of cleanup, expand its effi-
ciency and activity, improve the
quality of the program over time,
and build public confidence. There
are no miracle cures for the hazard-
ous waste problem. But EPA has a
clear and cogent strategy for meet-
ing this challenge beyond this
century and into the next millen-
nium.
36
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EPA
Superfund
Offices
U.S. Environmental Protection Agency
Office of Emergency & Remedial Response
401M Street, SW
Washington, D.C. 20460
CML (Commercial): (202) 382-2090
FTS (Federal Telecommunications
System): 382-7883
EPA Region 1
Waste Management Division
JFK Federal Building
Boston, Massachusetts 02203
CML: (617)565-3715
FTS: 835-3715
EPA Region 2
Emergency & Remedial Response Division
Jacob K. Javitz Federal Building
26 Federal Plaza
New York, New York 10278
CML: (212)264-2657
FTS: 264-2657
EPA Region 3
Hazardous Waste Management Division
841 Chestnut Building
Philadelphia, Pennsylvania 19107
CML: (215) 597-9800
FTS: 597-9800
EPA Region 4
Waste Management Division
345 Courtland Street, NE
Atlanta, Georgia 30365
CML: (404)347-4727
FTS: 257-4727
,0
EPA Region 5
Waste Management Division
230 South Dearborn Street
Chicago, Illinois 60604
CML: (312)353-2000
FTS: 353-2000
EPA Region 6
Hazardous Waste Management Division
First Interstate Bank Tower at Fountain Place
1445 Ross Avenue, 12th Floor, Suite 1200
Dallas, Texas 75202
CML: (214)655-6444
FTS: 255-6444
EPA Region 7
Waste Management Division
726 Minnesota Avenue
Kansas City, Kansas 66101
CML: (913)551-7000
FTS: 276-7003
EPA Region 8
Hazardous Waste Management Division
99918th Street, Suite 500
Denver, Colorado 80202-2405
CML: (303)293-1603
FTS: 330-1603
EPA Region 9
Hazardous Waste Management Division
75 Hawthorne Street
San Francisco, California 94105
CML: (415)744-1500
FTS: 484-1020
EPA Region 10
Hazardous Waste Division
1200 Sixth Avenue
Seattle, Washington 98101
CML: (206)442-1200
FTS: 399-1200
-------
For More Information
Dockets
Maintain the official rulemaking files, which include
official statements of the Administrator's position,
transcripts of hearings, litigation records, and public
comments.
RCRA Docket And Information Center: Contains
rulemaking files, publications, and background docu-
ments concerning the Resource Conservation and
Recovery Act.
(202) 475-9327
Superfund Docket: Provides rulemaking files, back-
ground documents, and viewing copies of Records of
Decision concerning the Comprehensive Environmental
Response, Compensation, and Liability Act.
(202) 382-3046
Superfund Documents Center: Manages all aspects of
document production, distribution, archiving, and
maintenance of bibliography. Ensures that the bibliogra-
phy is available to the public through the National
Technical Information Service (NTIS) and provides
document inventory service to agency staffs. Write
Superfund Documents Center-OS-240.
Public Information Center: Maintains a broad spec-
trum of EPA program publications of general environ-
mental interest, available to the public upon request.
Public Information Center
U.S.EPA(PM-211B)
401M Street, SW
Washington, DC 20460
(202) 382-2080 or 475-7751
Hotlines
Provide information to the public and the regulated
community in interpreting regulations and policies.
RCRA/CERCLA: Responds to questions from the
public and the regulated community on the Resource
Conservation and Recovery Act, and the Comprehensive
Environmental Response, Compensation, and Liability
Act (Superfund). Hours of operation are Monday
through Friday, 8:30 a.m. to 7:30 p.m. Eastern Time.
(800)424-9346
(703) 920-9810 in the Washington, DC area
(800) 553-7672 TDD
Emergency Planning And Community Right-To-
Know: Provides communities and individuals with help
in preparing for accidental releases of toxic chemicals.
This hotline is maintained as an information resource
rather than an emergency number, and serves to comple-
ment the RCRA/CERCLA Hotline.
(800) 535-0202
Libraries
The EPA Headquarters library maintains a variety of
reference materials, data bases, and both general and
special collections on environmental topics, including
hazardous waste.
Headquarters Library
EPA, Room M2904
401 M Street, SW
Washington, DC 20460
(202) 382-5921
In addition to the Headquarters library, there is a library
in each of EPA's ten Regional Offices (the addresses
appear on the "EPA Superfund Offices" page and the
telephone numbers are listed on the next page).
National Response Center (NRC)
Operated by the U.S. Coast Guard, this emergency
hotline is used to report spills of oil and other hazardous
materials. Calls are accepted 24 hours a day, every day
of the year.
(800) 424-8802
(202) 426-2675 in the Washington, DC area ,
Hazardous Waste Ombudsman
Assists citizens and the regulated community who have
had problems voicing a complaint or getting an issue
resolved about hazardous waste. There is a Hazardous
Waste Ombudsman at EPA Headquarters and one in each
of EPA's ten Regional Offices (addresses on page 37).
(703) 557-1938
Center For Environmental Research
Information (CERI)
Serves as a central point of distribution for EPA research
results and reports. Also conducts workshops and
seminars on environmental regulations, new technolo-
gies, and the health effects of environmental chemicals.
The Center plays a major role in Superfund research,
development, and response.
CERI
U.S. Environmental Protection Agency
Cincinnati, OH 45268
(513) 569-7391
38
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For More Information
For information on training for and response to hazard-
ous materials emergencies, contact the Technical Support
Division at (513) 569-7562.
National Technical Information
Service (NTIS)
A self supporting agency of the U.S. Department of
Commerce, NTIS serves as a repository for more than
1.6 million technical reports, summarizing government,
university, and corporate research worldwide. In addi-
tion to providing public access to the entire Superfund
bibliography, NTIS also maintains Superfund computer
datafiles, providing up-to-date information including the
names and locations of potential hazardous waste sites
reported to EPA.
U.S. Department of Commerce
NTIS
5285 Port Royal Road
Springfield, VA 22161
(703) 487-4650
Regional Offices
EPA has ten Regional Offices to provide the public with
both general and technical information about specific
environmental issues in the States they oversee.
EPA Region 1:
EPA Region 2:
EPA Region 3:
EPA Region 4:
Connecticut, Massachusetts,
Maine, Vermont, New Hampshire,
Rhode Island
General Number: (617)565-3715
Hazardous Waste Ombudsman:
(617) 565-3394
New Jersey, New York, Puerto Rico,
Virgin Islands
General Number: (212) 264-2657
Hazardous Waste Ombudsman:
(212)264-4711
Delaware, Maryland, Pennsylvania,
Virginia, West Virginia,
District of Columbia
General Number: (215) 597-9800
Hazardous Waste Ombudsman:
(215) 597-0982
Alabama, Florida, Georgia, Ken-
tucky, Mississippi, North Carolina,
South Carolina, Tennessee
General Number: (404) 347-4727
EPA Region 5:
EPA Region 6:
EPA Region 7:
EPA Region 8:
EPA Region 9:
EPA Region 10:
(800) 282-0239 in GA; (800) 241-
1754 in other Region 4 States
Hazardous Waste Ombudsman:
(404) 347-3004
Illinois, Indiana, Michigan,
Minnesota, Ohio, Wisconsin
General Number: (312) 353-2000
(800) 572-2515 in IL; (800) 621-
8431 in other Region 5 States
Hazardous Waste Ombudsman:
(312)353-5821
Arkansas, Louisiana, New Mexico,
Oklahoma, Texas
General Number: (214) 655-6444
Environmental Emergency Hotline -
24 hours: (214)655-2222
Hazardous Waste Ombudsman:
(214) 655-6765
Iowa, Kansas, Missouri, Nebraska
General Number: (913) 551-7000
Hazardous Waste Ombudsman:
(913) 551-7051
Colorado, Montana, North Dakota,
South Dakota, Utah, Wyoming
General Number: (303) 293-1603;
(800) 759-4372
Hazardous Waste Ombudsman:
(303)294-1111
Arizona, California, Hawaii,
Nevada, American Samoa, Guam,
Commonwealth of the Northern
Mariana Islands, Republic of Palau,
Federated States of Micronesia, the
Republic of the Marshall Islands
General Number: (415) 744-1500
RCRA Hotline: (415) 744-2074
Superfund Hotline: (800) 231-3075
Hazardous Waste Ombudsman:
(415) 744-1470
Alaska, Idaho, Oregon, Washington
General Number: (206) 442-1200
Hazardous Waste Ombudsman:
(206) 442-2871
39
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Glossary of Terms
Administrative Order on Consent (AOC): An admin-
istrative legal agreement between EPA and potentially
responsible parties (PRPs) whereby PRPs agree to
perform or pay the cost of a site response action. The
agreement describes actions to be taken at a site and may
be subject to a public comment period. Unlike a consent
decree, an AOC does not have to be approved by a judge.
Administrative Record: A file that contains all infor-
mation used by the lead agency to make its decision on
the selection of a response action under CERCLA. This
file is available for public review and a copy is estab-
lished at or near the site, usually at one of the informa-
tion repositories. Also, a duplicate file is held in a
central location, such as a Regional or State office.
Affected Public: The people who live and/or work near
hazardous waste sites.
Agency for Toxic Substances and Disease Registry
(ATSDR): A Federal agency within the Department of
Health and Human Services which, in conjunction with
EPA, is responsible for implementing health-related
authorities of CERCLA, including conducting site-
specific health assessments.
Alternative Remedial Contract Strategy (ARCS)
Contractors: Government contractors who provide
project management and technical services to support
remedial response activities at National Priorities List
sites.
Applicable or Relevant and Appropriate Require-
ments (ARARs): ARARs include any State or Federal
statute or regulation that pertains to protection of human
health and the environment in addressing certain site
conditions or using a particular cleanup technology at a
Superfund site. A State law to preserve wetland areas is
an example of an ARAR. EPA must consider whether a
remedial alternative meets ARARs as part of the process
for selecting a cleanup alternative for a Superfund site.
Availability Session: An informal meeting in a public
location where interested citizens can talk with EPA and
State officials on a one-to-one basis.
Bench-Scale Tests: Laboratory testing of potential
cleanup technologies (also known as treatability studies).
Biorcmediation: The use of living organisms, such as
bacteria and fungi, to treat hazardous substances.
Brine Mud: A waste material, often associated with
well drilling or mining, composed of mineral salts and
other inorganic compounds.
Cap: A layer of clay or other highly impermeable
material installed over the top of a closed landfill to
prevent entry of rainwater and minimize leakage.
Carbon Tetrachloride: A colorless liquid used in
refrigerants, metal degreasers, agricultural fumigants,
and as a dry-cleaning agent. Exposure to it can cause
damage to the central nervous system, liver, and kidneys.
Clean Water Act: Federal law regulating the discharge
of pollutants into surface waters.
Cleanup: Actions taken to deal with a release or threat-
ened release of hazardous substances to protect human
health and/or the environment.
Community Relations: EPA's program to inform and
involve the public in the Superfund process and respond
to community concerns.
Community Relations Coordinator (CRC): The EPA
official responsible for overseeing and directing commu-
nity relations activities.
Community Relations Plan (CRP): The document that
outlines specific community relations activities that
occur during a remedial response at a site. The CRP
outlines how EPA will keep the public informed of work
at the site and the ways in which citizens can review and
comment on decisions that may affect the final actions at
the site.
Comprehensive Environmental Response, Compensa-
tion, and Liability Act (CERCLA): A Federal law
passed in 1980 and amended in 1986 by the Superfund
Amendments and Reauthorization Act. CERCLA
created a special tax that goes into a Trust Fund, com-
monly known as Superfund, to investigate and clean up
abandoned or uncontrolled hazardous waste sites. Under
the program, EPA can either:
• Perform site cleanup when parties responsible
for the contamination cannot be located or are
unwilling or unable to perform the work; or
• Take legal action to force parties responsible for
site contamination to clean up the site or pay
back the Federal government for the cost of the
cleanup.
40
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Glossary of Terms
Comprehensive Environmental Response, Compensa-
tion, and Liability Information System (CERCLIS):
The official information system for the Superfund
program, it contains site-specific and general program
data, such as site location, technical cleanup process,
scheduled activities, and costs to date.
Consent Decree: A legal document, approved and
issued by a State or Federal district court, that formalizes
an agreement between a State or EPA and potentially
responsible parties (PRPs) whereby PRPs will perform
all or part of a Superfund site cleanup. The consent
decree describes actions that PRPs are required to
perform and is subject to a public comment period.
Cooperative Agreement (CA): An assistance agree-
ment whereby EPA transfers money, property, services,
or anything of value to a State for the accomplishment of
certain activities or tasks as authorized by CERCLA.
Core Program Cooperative Agreement (CPCA): An
assistance agreement whereby EPA provides support
funds to States and Indian Tribes to help defray the cost
of non-site-specific activities, such as administrative and
clerical salaries, computer resources, and training.
Cost Recovery: A legal process through which poten-
tially responsible parties can be required to pay back the
Federal government for money it spends on any cleanup
actions.
Covenant Not to Sue: A written agreement that releases
settling potentially responsible parties from present or
future liability.
De Minimis Settlements: Settlements that are smaller
agreements separate from the larger settlement for the
chosen cleanup remedy. Under de minimis settlements,
contributors of a relatively small amount of waste to a
site, or landowners who bought the site but did not
contribute wastes to it, may resolve their liability.
Department of Defense (DOD): The U.S. Army Corps
of Engineers within DOD has specialized equipment and
personnel available to assist in removal actions. The
Corps serves as EPA's primary agent for Federal-lead
remedial designs and remedial actions.
Department of Energy (DOE): DOE provides special
assistance when radioactive substances are involved at
Superfund sites.
Department of Justice (DOJ): DOJ assists EPA in
enforcement activities and legally represents EPA when
cases go to court.
Emergency Preparedness and Community Right-to-
Know Act (EPCRA): A Federal law that established a
four-part program to define an emergency planning
structure at the State and local levels; require emergency
notification of hazardous chemical releases; require
notification of chemical use, storage, or production
activities; and define annual emissions reporting require-
ments.
Enforcement: EPA's efforts, through legal action if
necessary, to force potentially responsible parties to
respond to information requests or perform or pay for a
Superfund site cleanup.
Fact Sheet: A document prepared and distributed by
EPA to inform the public of Superfund site or program
activities.
Feasibility Study (FS): See Remedial Investigation/
Feasibility Study.
Future Liability: Refers to potentially responsible
parties' obligations to pay for additional response
activities beyond those specified in the Record of Deci-
sion or consent decree.
Gas Chromatograph/Mass Spectrometer: A highly
sophisticated instrument that identifies the molecular
composition and concentrations of the various chemicals
in water and soil samples.
General Notice Letter: A letter, issued by EPA, advis-
ing potentially responsible parties of their potential
liability at a Superfund site.
Ground Water: Water found beneath the earth's
surface that fills pores between materials such as sand,
soil, or gravel. Ground water can occur in sufficient
quantities that it can be used for drinking water, irriga-
tion, and other purposes.
Hazard Ranking System (HRS): A scoring system
used to evaluate potential relative risks to human health
and the environment from releases or threatened releases
of hazardous substances. EPA and States use the HRS to
calculate a site score, from 0 to 100, based on the actual
or potential release of hazardous substances from a site
through air, surface water, or ground water.
41
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Glossary of Terms
Hazardous Substance: Any material that poses a threat
to human health and/or the environment. Typical
hazardous substances are materials that are toxic, corro-
sive, ignitable, explosive, or chemically reactive.
Hazardous Waste: By-products or wastes that are toxic,
corrosive, ignitable, explosive, or chemically reactive.
Although the legal definition of hazardous waste is
complex, the term more generally refers to any waste that
EPA believes could pose a threat to human health and the
environment if improperly treated, stored, transported, or
disposed.
Health Assessment: A study, required by CERCLA and
performed by the Agency for Toxic Substances and
Disease Registry (ATSDR), that determines the potential
risks to human health posed by a site.
In-sltu Stripping: A treatment system that removes or
"strips" volatile organic compounds from contaminated
ground water or surface water by forcing an airstream
through the water and causing the compounds to evapo-
rate.
Information Exchange: A phase that occurs early in the
negotiation process through which EPA and potentially
responsible parties exchange information and knowledge
about past activities at a Superfund site.
Information Repository: A file containing current
information, technical reports, and reference documents
regarding a Superfund site. The information repository is
usually located in a public building that is convenient for
local residents, such as a public school, library, or city
hall.
Innovative Technologies: New or inventive methods to
treat effectively hazardous waste and reduce risks to
human health and the environment.
Inorganic Compounds: Compounds composed of
mineral materials, including elemental salts and metals
such as iron, aluminum, mercury, and zinc.
Local Governments Reimbursement (LGR) Program:
An EPA program that provides up to $25,000 directly to
local governments to help ease the financial burden of
conducting temporary emergency measures in response
to a hazardous substance threat.
Long-Term Contracting Strategy: Refers to EPA's
efforts to analyze the long-term contracting needs of the
Superfund program and design or realign contracts to
meet those needs.
Management Review of the Superfund Program (90-
Day Study): An EPA report, commissioned by the EPA
Administrator and published in May 1989, that provides
an assessment of the Superfund program and suggests a
practical strategy for realizing the greatest environmental
benefit possible, given the long-term, incremental nature
of Superfund.
Media: Components of the environment, including
surface water, ground water, soil, and air, which are the
subject of regulatory concern and activities.
Mercury: A silver, liquid metal that is highly toxic and
can be absorbed through the skin. It is used in ther-
mometers, batteries, fluorescent light bulbs, pharmaceuti-
cals, and many other products.
Metals: Compounds such as chromium and lead that can
be toxic at relatively low concentrations.
Mixed Funding: Settlements in which potentially
responsible parties and EPA share the costs of the
response action.
Monitoring Wells: Special wells drilled at specific
locations on or off a hazardous waste site where ground
water can be sampled at selected depths and studied to
determine such things as the direction of ground water
flow and the types and amounts of contaminants present.
Moratorium: During the negotiation process, a period
of 60 or 90 days during which EPA and potentially
responsible parties may reach settlement but no site
response activities can be conducted.
National Oil and Hazardous Substances Pollution
Contingency Plan (NCP): The Federal regulation that
provides a blueprint for Superfund program operations.
National Priorities List (NPL): EPA's list of the most
serious uncontrolled or abandoned hazardous waste sites
identified for possible long-term remedial response using
money from the Trust Fund. The list is based primarily
on the score a site receives from the Hazard Ranking
System. EPA is required to update the NPL at least once
a year.
42
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Glossary of Terms
National Response Center (NRC): The center operated
by the U.S. Coast Guard that receives and evaluates
reports of oil and hazardous substance releases into the
environment and notifies the appropriate agency(ies).
The NRC can be contacted 24 hours a day, toll-free at
800-424-8802.
National Response Team (NRT): Representatives of
14 Federal agencies that coordinate Federal responses to
nationally significant pollution incidents and provide
advice and technical assistance to the responding
agency (ies).
Negotiations: After potentially responsible parties
(PRPs) are identified for a site, EPA coordinates with
them to reach a settlement. Negotiated settlements result
in PRPs paying for or conducting cleanup activities
under EPA supervision. If negotiations fail, EPA can
order the PRPs to conduct the cleanup or EPA can pay
for the cleanup using Superfund monies and then sue the
PRPs to recover costs.
No Further Remedial Action Planned (NFRAP): A
determination made by EPA following a preliminary
assessment that a site does not pose a significant risk and
so requires no further activity under CERCLA.
Non-Binding Allocations of Responsibility (NEAR):
Process for EPA to propose a way for potentially respon-
sible parties to allocate costs among themselves.
Non-compliance: If a potentially responsible party
(PRP) does not meet the agreement set forth in a negoti-
ated settlement, the PRP is in "non-compliance" and
EPA can invoke penalties, usually in the form of fines.
On-Scene Coordinator (OSC): The Federal official
who coordinates and directs Superfund removal actions.
Operable Unit (OU): An action taken as one part of an
overall site cleanup. For example, a carbon absorption
system could be installed to halt rapidly spreading
ground water contaminants while a more comprehensive
and long-term remedial investigation/feasibility study is
underway. A number of OUs can be used in the course
of site cleanup.
Operation & Maintenance (O&M): Activities con-
ducted at a site after a response action has concluded, to
ensure that the cleanup or containment system is func-
tioning properly.
Organic Compounds: Chemical compounds composed
of carbon and hydrogen, including materials such as oils,
pesticides, and solvents.
Pilot Tests: Testing of a cleanup technology, performed
under actual site conditions, to identify potential prob-
lems prior to full-scale implementation.
Political Subdivision: The definition of political
subdivision varies from State to State, so each State
determines what units of government meet its legislative
definition. A political subdivision can participate in
Superfund cleanup as a lead or support agency when
EPA and the State agree that this enhances the cleanup
process and results in an efficient, economical, and well-
coordinated use of resources.
Poly chlorinated Biphenyls (PCBs): A family of
organic compounds used since 1926 in electric trans-
formers as insulators and coolants, in lubricants, carbon-
less copy paper, adhesives, and caulking compounds.
PCBs do not break down into new and less harmful
chemicals and are stored in the fatty tissues of humans
and animals. EPA banned the use of PCBs in 1979.
Potentially Responsible Party (PRP): An individual(s)
or company(ies) (such as owners, operators, transporters,
or generators) potentially responsible for, or contributing
to, the contamination problems at a Superfund site.
Whenever possible, EPA requires PRPs, through admin-
istrative and legal actions, to clean up hazardous waste
sites they have contaminated.
Potentially Responsible Party (PRP) Search: An
investigation, conducted by a State or EPA, into the
parties who may be liable for the cleanup at a site. The
PRP search enhances EPA's success in negotiating with
PRPs to conduct a response action under EPA's supervi-
sion.
Preliminary Assessment (PA): The process of collect-
ing and reviewing available information about a known
or suspected hazardous waste site or release. EPA or
States use this information to determine if the site
requires further study. If further study is needed, a site
inspection is undertaken.
Present Liability: Refers to a potentially responsible
party's obligation to pay response costs already incurred
by the government and to complete remedial activities
set forth in the Record of Decision or consent decree.
43
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Glossary of Terms
Proposed Plan: A plan for site cleanup that is available
to the public for comment. It highlights key aspects of
the remedial investigation/feasibility study report,
provides a brief analysis of remedial alternatives under
consideration, identifies the preferred alternative, and
provides members of the public with information on how
they can participate in the remedy selection process.
Public Comment Period: A time period during which
the public can review and comment on various docu-
ments and EPA actions. For example, a comment period
is provided when EPA proposes to add sites to the
National Priorities List. Also, a minimum 30-day
comment period is held to allow community members to
review and comment on a draft feasibility study and
Proposed Plan.
Record of Decision (ROD): A public document that
explains which cleanup alternative(s) will be used at a
National Priorities List site. The ROD is based on
information and technical analysis generated during the
remedial investigation/feasibility study and consideration
of public comments and community concerns.
Records of Decision System (RODS): A detailed data
base of ROD information used to promote national
consistency of remedies chosen at similar sites.
Remedial Action (RA): The actual construction or
implementation phase that follows the remedial design of
the selected cleanup alternative at a site on the National
Priorities List.
Remedial Design (RD): An engineering phase that
follows the Record of Decision when technical drawings
and specifications are developed for the subsequent
remedial action at a site on the National Priorities List.
Remedial Investigation/Feasibility Study (RI/FS):
Investigative and analytical studies usually performed at
the same time in an interactive process, and together
referred to as the RI/FS. They are intended to:
• Gather die data necessary to determine the type
and extent of contamination at a Superfund site;
• Establish criteria for cleaning up the site;
• Identify and screen cleanup alternatives for
remedial action; and
• Analyze in detail the technology and costs of the
alternatives.
Remedial Project Manager (RPM): The EPA or State
official responsible for overseeing remedial response
activities.
Removal Action: A fast track action taken over the
short-term to control immediate threats to people and/or
the environment from a release or threatened release of
hazardous substances.
Removal Site Evaluation (RSE): A document that
determines if a removal action is necessary; the evalu-
ation is composed of the preliminary assessment and the
site inspection.
Reportable Quantities (RQs): The quantity of a
hazardous substance that, if released into the environ-
ment, may present substantial danger to the human health
or welfare or the environment and must be reported to
the National Response Center or EPA.
Responsiveness Summary: A summary of oral and/or
written public comments received by EPA during a
comment period on key EPA documents, and EPA's
responses to those comments. The responsiveness
summary is a key part of the Record of Decision, high-
lighting community concerns for EPA decisionmakers.
Revised Hazard Ranking System (rHRS): Modifica-
tions to the HRS, as required by the Superfund Amend-
ments and Reauthorization Act, that became effective
March 15, 1991.
Risk Assessment: An evaluation performed as part of
the remedial investigation to assess conditions at a
Superfund site and determine the risk posed to human
health and the environment.
Risk Reduction: EPA's efforts to reduce, control, or
eliminate human health, welfare, and ecological risks
posed by environmental problems.
Site Assessment Program: A means of evaluating
hazardous waste sites, through preliminary assessments
and site inspections, to develop a Hazard Ranking
System score that is used to determine if a site should be
placed on the National Priorities List.
Site Inspection (SI): A technical phase that follows a
preliminary assessment designed to collect more exten-
sive information on a hazardous waste site. The informa-
tion is used to score the site with the Hazard Ranking
System to determine whether a remedial action is needed.
44
-------
Glossary of Terms
Site Safety Plan: A crucial element of all removal
actions and the remedial design/remedial action phase of
remedial actions, it includes information on equipment
being used, precautions to be taken, and steps to take in
the event of an emergency situation at the site.
Sludge: A generic term that describes a thickened semi-
solid waste byproduct of an industrial or recycling
process.
Special Notice Letter: A letter, sent by EPA, that
initiates the process of formal enforcement negotiations,
and invokes a negotiation moratorium between PRPs and
EPA.
Strict, Joint and Several Liability: Strict liability
means that the Federal government can hold a potentially
responsible party (PRP) liable without showing that the
PRP was at fault. Joint and several liability means that
any one PRP can be held liable for the entire costs of site
cleanup, regardless of the share of waste contributed by
that PRP.
Superfund Amendments and Reauthorization Act
(SARA): Modifications to CERCLA enacted on October
17, 1986.
Superfund Innovative Technology Evaluation (SITE):
An EPA program designed to promote the development
and use of innovative treatment technologies to clean up
Superfund sites.
Superfund Memorandum of Agreement (SMOA): An
optional agreement that specifies the procedures that
EPA and a State or Indian Tribe will use to implement
CERCLA and the National Oil and Hazardous Sub-
stances Contingency Plan (NCP). These procedures then
serve as the basis for site-specific Cooperative Agree-
ments or Superfund State Contracts.
Superfund State Contract (SSC): A contract between
EPA and a State that is legally binding on both parties.
The SSC is used to document EPA and State responsi-
bilities and to obtain any necessary State assurances for
response actions.
Superfund: The common name used for the Compre-
hensive Environmental, Response, Compensation, and
Liability Act. Also referred to as the Trust Fund.
Technical Assistance Grant (TAG) Program: A
program that provides grants of up to $50,000 per
Superfund site so citizens can hire independent technical
advisors to help them understand information related to
cleaning up a site.
Thermal Treatment: The use of elevated temperatures
to treat hazardous waste by changing the chemical and/or
physical composition of the waste.
Total Quality Management (TQM): The application of
management techniques and statistical controls to a
process in order to improve any product "constantly and
forever."
Toxicological Profile: An examination, summary, and
interpretation of a hazardous substance to determine
levels of exposure and associated health effects.
Treatability Studies: Tests of potential cleanup tech-
nologies conducted in a laboratory (also known as bench-
scale tests).
Treble Damages: CERCLA provides that EPA can sue
potentially responsible parties (PRPs) for up to three
times the cost of cleanup, if the PRPs consistently do not
comply with a negotiated settlement.
Unilateral Administrative Order (UAO): An adminis-
trative legal document issued unilaterally by EPA
directing a potentially responsible party to perform site
cleanup. UAOs are typically issued when negotiations
between PRPs and EPA have broken off. It sets forth the
liability of the party for the cleanup, describes actions to
be taken, and subjects the recipient to penalties and
damages for noncompliance. Unilateral orders may be
enforced in court through judicial action.
U.S. Coast Guard (USCG): The USCG is responsible
for managing responses to oil spills and other hazardous
releases hi coastal waters and inland waterways. The
USCG operates the National Response Center.
Volatile Organic Compounds: Carbon-containing
chemical compounds that evaporate (volatilize) readily at
room temperature.
45
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-------
• Present physical state of the material (i.e., gas, liquid, solid)
• Total amount of material that may be released
• Other hazardous materials in area
• Amount of material released so far/duration of release
• Whether significant amounts of the material appear to be entering the atmos-
phere, nearby water, storm drains, or soil
• Direction, height, color, odor of any vapor clouds or plumes
• Weather conditions (wind direction and speed)
• Local terrain conditions
• Personnel at the scene
Comment: Initial information is critical. Answers to some of these questions may be
unknown by the caller, but it is important to gather as much information as
possible very quickly in order to facilitate decisions on public notification and
evacuation. Some questions will apply to fixed facility incidents and others
will apply only to transportation incidents. Some questions will apply specifi-
cally to air releases, while other questions will gather information about spills
onto the ground or into water. Identification numbers, shipping manifests,
and placard information are essential to identify any hazardous materials
involved in transportation incidents, and to take initial precautionary and con-
tainment steps. First responders should use DOT's Emergency Response
Guidebook to help identify hazardous materials. Additional information about
the identity and characteristics of chemicals is available by calling CHEMTREC
(800-424-9300). CHEMTREC and the Hazard Information Transmission
(HIT) program are described in Appendix C.
This emergency response notification section should be:
BRIEF — never more than one page in length.
EASILY ACCESSIBLE — located on the cover or first page of the plan. It
should also be repeated at least once inside the plan, in case the cover is
torn off.
SIMPLE — reporting information and emergency telephone numbers should
be kept to a minimum.
Copies of the emergency response notification form could be provided to
potential dischargers to familiarize them with information needed at the time
of an incident.
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Planning Element A.2: Promulgation Document
D Statement of plan authority ;
Comment: A letter, signed by the community's chief executive, should indicate legal
authority and responsibility for putting the plan into action. To the extent that
the execution of this plan involves various private and public-sector organiza-
tions, it may be appropriate to include here letters of agreement signed by
officials of these organizations. ;
Planning Element A.3: Legal Authority and Responsibility
for Responding
D Authorizing legislation and regulations •
• Federal (e.g., CERCLA, SARA, Clean Water Act, National Contingency Plan, and
Disaster Relief Act) .
• State :
• Regional
• Local
D Mandated agency responsibilities
D Letters of agreement •.
Comment: If there are applicable laws regarding planning for response to hazardous
materials releases, list them here. Analyze the basic authority of participat-
ing agencies and summarize the results here. The community may choose
to enact legislation in support of its plan. Be sure to identify any agencies
required to respond to particular emergencies.
Planning Element A.4: Table of Contents
Comment: All sections of the plan should be listed here and clearly labeled with a tab for
easy access. ;
Planning Element A.5: Abbreviations and,Definitions
Comment: Frequently used abbreviations, acronyms, and definitions should be gathered
here for easy reference. •
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Planning Element A.6: Assumptions/Planning Factors
Q- Geography
• Sensitive environmental areas
• Land use (actual and potential, in accordance with local development codes)
• Water supplies
• Public transportation network (roads, trains, buses)
• Population density
• Particularly sensitive institutions (e.g., schools, hospitals, homes for the aged)
D Climate/weather statistics
D Time variables (e.g., rush hour, vacation season)
D Particular characteristics of each facility and the transportation routes for which the
plan is intended
• On-site details
• Neighboring population
• Surrounding terrain
• Known impediments (tunnels, bridges)
• Other areas at risk
D Assumptions
Comment: This section is a summary of precisely what local conditions make an emer-
gency plan necessary. Information for this section will be derived from the
hazards identification and analysis. Appropiate maps should be included in
this section. Maps should show: water intake, enviromentally sensitive areas,
major chemical manufacturing or storage facilities, population centers, and
the location of response resources.
Assumptions are the advance judgments concerning what would happen in
the case of an accidental spill or release. For example, planners might as-
sume that a certain percentage of local residents on their own will evacuate
the area along routes other than specified evacuation routes.
Planning Element A.7: Concept of Operations
Planning Element A.7a: Governing Principles
Comment: The plan should include brief statements of precisely what is expected to be
accomplished if an incident should occur.
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Planning Element A.7b: Organizational Roles and Responsibilities
O Municipal government |
• Chief elected official
• Emergency management director
• Community emergency coordinator (Title III of SARA) ;
• Communications personnel
• Fire service ;
i
• Law enforcement
• Public health agency :
• Environmental agency
• Public works ;
O County government ;
i ,
a Officials of fixed facilities and/or transportation companies ;
i
• Facility emergency coordinators (Title III of SARA) i
D Nearby municipal and county governments
D Indian tribes within or nearby the affected jurisdiction -
D State government ;
• Environmental protection agency '
• Emergency management agency
• Public health agency ',
i
• Transportation organization
• Public safety organization
D Federal government
• EPA
• FEMA
i
• DOT '•
• HHS/ATSDR
• USCG
• DOL/OSHA
i
Page 44 \
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• DOD
• DOE
• RRT
D Predetermined arrangements
D How to use outside resources
• Response capabilities
• Procedures for using outside resources
Comment: This section lists all those organizations and officials who are responsible for
planning and/or executing the pre-response (planning and prevention), re-
sponse (implementing the plan during an incident), and post-response
(cleanup and restoration) activities to a hazardous materials incident. One
organization should be given command and control responsibility for each
of these three phases of the emergency response. The role of each organi-
zation/official should be clearly described.The plan should clearly designate
who is in charge and should anticipate the potential involvement of State and
Federal agencies and other response organizations. (Note: The above list of
organizations and officials is not meant to be complete. Each community will
need to identify all the organizations/officials who are involved in the local
planning and response process.)
This section of the plan should contain descriptions and information on the
RRTs and the predesignated Federal OSC for the area covered by the plan.
(See Section 1.4.1 of this guidance.) Because of their distant location, it is
often difficult for such organizations to reach a scene quickly; planners
should determine in advance approximately how much time would elapse be-
fore the Federal OSC could arrive at the scene.
This section should also indicate where other disaster assistance can be ob-
tained from Federal, State, or Regional sources. Pre-arrangements can be
made with higher-level government agencies, bordering political regions,
and chemical plants.
Major hazardous materials releases may overwhelm even the best prepared
community, and an incident may even cross jurisdictional boundaries. Coop-
erative arrangements are an efficient means of obtaining the additional per-
sonnel, equipment, and materials that are needed in an emergency by re-
ducing expenditures for maintaining extra or duplicative resources. Any co-
ordination with outside agencies should be formalized through mutual aid and
Good Samaritan agreements or memoranda of understanding specifying
delegations of authority, responsibility, and duties. These formal agreements
can be included in the plan if desired.
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Planning Element A.7c: Relationship to Other Plans
Comment: A major task of the planning group is to integrate planning for hazardous
materials incidents into already existing plans. In larger communities, it is
probable that several emergency plans have been prepared. It is essential
to coordinate these plans. When more than one plan is put into action si-
multaneously, there is a real potential for confusion among response person-
nel unless the plans are carefully coordinated. All emergency plans (includ-
ing facility plans and hospital plans) that might be employed in the event of
an accidental spill or release should be listed in this section. The community
plan should include the methods and procedures to be followed by facility
owners and operators and local emergency response personnel to respond
to any releases of such substances. The NCR, the Federal Regional contin-
gency plan, any OSC plan for the area, and any State plan should be refer-
enced. Of special importance are all local emergency plans.
Even where formal plans do not exist, various jurisdictions often have prepar-
edness capabilities. Planners should seek information about informal agree-
ments involving cities, counties, States, and countries.
Planning Element A.8: Instructions on Plan Use
Planning Element A.8a: Purpose
Comment: This should be a clear and succinct statement of when and how the plan is
meant to be used. It is appropriate to list those facilities and transportation
routes explicitly considered in the plan. :
Plan Section A.8b: Plan Distribution
D List of organizations/persons receiving plan
Comment: The entire plan should be available to the public; it can be stored at a library,
the local emergency management agency, or some other public place. The
plan should be distributed to all persons responsible for response operations.
The plan distribution list should account for all organizations receiving such
copies of the plan. This information is essential when determining who
should be sent revisions and updates to the plan.
Page 46
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w'w-WAWW«w,wdww/^
Planning Element A.9: Record of Amendments
a Change record sheet
• Date of change
• Recording signature
• Page numbers of changes made
Comment: Maintaining an up-to-date version of a plan is of prime importance. When
corrections, additions, or changes are made, they should be recorded in a
simple bookkeeping style so that all plan users will be aware that they are
using a current plan.
All that is necessary for this page is a set of columns indicating date of
change, the signature of the person making the change, and the page num-
ber for identifying each change made.
Planning Element B: Emergency Assistance Telephone Roster
D List of telephone numbers for:
• Participating agencies
• Technical and response personnel
• CHEMTREC
• Public and private sector support groups
• National Response Center
Comment: An accurate and up-to-date emergency telephone roster is an essential
item. The name of a contact person (and alternate) and the telephone num-
ber should be listed. Briefly indicate the types of expertise, services, or
equipment that each agency or group can provide. Indicate the times of day
when the number will be answered; note all 24-hour telephone numbers. All
phone numbers and names of personnel should be verified at least every six
months. When alternate numbers are available, these should be listed. This
section of the plan should stand alone so that copies can be carried by emer-
gency response people and others. Examples of organizations for possible
inclusion in a telephone roster are as follows:
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Telephone Roster
Response Personnel
Incident Commander
Agency Coordinators
Response Team Members
Bordering Political Regions
Municipalities
Counties i
States i
Countries;
River Basin Authorities
Irrigation Districts
Interstate Compacts
Regional Authorities
Bordering International Authorities
Sanitation Authorities/Commissions
Industry
Transporters
Chemical; Producers/Consumers
Spill Cooperatives
Spill Response Teams
Community Assistance
Police
Fire
Emergency Management Agency
Public Health Department
Environmental Protection Agency
Department of Transportation
Public Works
Water Supply
Sanitation
Port Authority
Transit Authority
Rescue Squad
Ambulance
Hospitals
Utilities:
Gas
Phone
Electricity
Community Officials
Mayor
City Manager
County Executive
Councils of Government
Volunteer Groups
Red Cross
Salvation Army
Church Groups
Ham Radio Operators
Off-Road Vehicle Clubs
State Assistance
State Emergency Response Commission (Title
State Environmental Protection Agency
Emergency Management Agency
Department of Transportation ;
Police '
Public Health Department
Department of Agriculture
Federal Assistance (Consult Regional offices listed in Appendix F for appropriate tele-
phone numbers.)
Federal On-Scene Coordinator ;
U.S. Department of Transportation
U.S. Coast Guard
U.S. Environmental Protection Agency
Media
Television
Newspaper
Radio '
of SARA)
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Federal Emergency Management Agency
U.S. Department of Agriculture
Occupational Safety and Health Administration
Agency for Toxic Substances and Disease Registry
National Response Center
in Washington,
U.S. Army, Navy, Air Force
Bomb Disposal and/or Explosive
Ordnance Team, U.S. Army
Nuclear Regulatory Commission
U.S. Department of Energy
Radiological Assistance
U.S. Department of the Treasury
Bureau of Alcohol, Tobacco, and Firearms
Other Emergency Assistance
CHEMTREC
CHEMNET
CHLOREP
NACA Pesticide Safety Team
Association of American Railroads/
Bureau of Explosives
Poison Control Center
Cleanup Contractor
24 hours
24 hours
24 hours
DC area
or
24 hours
24 hours
24 hours
24 hours
24 hours
24 hours
24 hours
202-646-2400
404-452-4100
800-424-8802
202-426-2675
202-267-2675
301-951-0550
202-586-8100
800-424-9300
800-424-9300
800-424-9300
800-424-9300
202-639-2222
Planning Element C: Response Functions
Comment: Each function should be clearly marked with a tab so that it can be located
quickly. When revising and updating a plan, communities might decide to
add, delete, or combine individual functions.
Each response "function" usually includes several response activities. Some
communities prepare a matrix that lists all response agencies down the left
side of the page and all response activities across the top of the page.
Planners can then easily determine which response activities need inter-
agency coordination and which, if any, activities are not adequately provided
for in the plan.
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Function 1: Initial Notification of Response Agencies
i
D 24-hour emergency response hotline telephone numbers !
• Local number to notify area public officials and response personnel
• Number to notify State authorities j
• National Response Center (800-424-8802; 202-426-2675 or 202-267-2675 in
Washington, DC area)
O Other agencies (with telephone numbers) to notify immediately (e.g., hospitals,
health department, Red Cross)
Comment: The local 24-hour emergency response hotline should be called first and
therefore should have a prominent place in the plan. Provision should be
made for notifying nearby municipalities and counties that could be affected
by a vapor cloud or liquid plumes in a water supply.
Normally, the organization that operates the emergency response hotline will
inform other emergency service organizations (e.g., health department, hos-
pitals, Red Cross) once the initial notification is made. The plan should pro-
vide a method for notifying all appropriate local, State, and Federal officials
and agencies, depending upon the severity of the [incident. To ensure that
the appropriate Federal On-Scene Coordinator (OSC) is notified of a spill or
release, the NRC operated by the U.S. Coast Guard should be included in the
notification listing. CERCLA requires that the NRC be notified by the responsi-
ble party of releases of many hazardous materials in compliance with the
reportable quantity (RQ) provisions. The NRC telephone number is
800-424-8802 (202-426-2675 or 202-267-2675 in the Washington, DC,
area). If there is an emergency notification number at the State or Regional
level, it should be called before the NRC, and then a follow-up call made to
the NRC as soon as practicable. j
The plan should indicate how volunteer and off-du|ty personnel will be sum-
moned. Similarly, there should be a method to notify special facilities (e.g.,
school districts, private schools, nursing homes, day care centers, indus-
tries, detention centers), according to the severity of the incident.
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Function 2: Direction and Control
D Name of on-scene authority
D Chain of command (illustrated in a block diagram)
D Criteria for activating emergency operating center
D Method for establishing on-scene command post and communications network for
response team(s)
D Method for activating emergency response teams
D List of priorities for response actions
D Levels of response based on incident severity
Comment: Response to a hazardous materials spill or release will involve many partici-
pants: police, firefighters, facility personnel, health personnel, and others. It
is also possible to have more than one organization perform the same serv-
ice; for example, local police, the county sheriff and deputies, as well as the
highway patrol may respond to perform police functions. Because speed of
response is so important, coordination is needed among the various agen-
cies providing the same service. It is essential to identify (by title or position)
the one individual responsible for each participating organization, and the one
individual responsible for each major function and service. The plan might
require that the responsible person establish an Incident Command System
(ICS).
Work out, in advance, the following:
(1) Who will be in charge (lead organization)
(2) What will be the chain of command
(3) Who will activate the emergency operating center, if required
(4) Who will maintain the on-scene command post and keep it secure
(5) Who will have advisory roles (and what their precise roles are)
(6) Who will make the technical recommendations on response actions to
the lead agency
(7) Who (if anyone) will have veto power
(8) Who is responsible for requesting assistance from outside the commu-
nity
This chain of command should be clearly illustrated in a block diagram.
Response action checklists are a way of condensing much useful information.
They are helpful for a quick assessment of the response operation. If check-
lists are used, they should be prepared in sufficient detail to ensure that all
crucial activities are included.
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Planners should consider whether to have categories of response actions
based on severity. The severity of an incident influences decisions on the
level (or degree) of response to be made. This will determine how much
equipment and how many personnel will be called, the extent of evacuation,
and other factors. j
The following chart summarizes who and what are'involved in three typical
emergency conditions. Information about the three response levels should
be provided to special facilities (e.g., school districts, private schools, day
care centers, hospitals, nursing homes, industries, detention centers).
Response Level
I. Potential
Emergency
Condition
II. Limited
Emergency
Condition
III. Full
Emergency
Condition
Description
An incident or threat of a
release which can be con-
trolled by the first response
agencies and does not require
evacuation of other than the
involved structure or the
immediate outdoor area. The
incident is confined to a
small area and does not pose
an immediate threat to life or
property.
An incident involving a
greater hazard or larger area
which poses a potential
threat to life or property
and which may require a
limited evacuation of the
surrounding area.
An incident involving a severe
hazard or a large area which
poses an extreme threat to
life and property and will
probably require a large scale
evacuation; or an incident
requiring the expertise or
resources of county, State,
Federal, or private agencies/
organizations.
Contact:
Fire Department
Emergency Medical
Services
Police Department
Partial EOC Staff
Public Information Office
CHEMTREC
National Response
; Center
All Agencies in
Level I
HAZMAT Teams
EOC Staff
Public Works
Department
Health Department
Red Cross
County Emergency
Management Agency
State Police
Public Utilities
All Level I and II Agencies
plus the following as
: needed:
Mutual Aid Fire, Police.
Emergency Medical
State Emergency
Management Agency
State Department of
: Environmental Resources
State Department of
Health
EPA
USCG
ATSDR
FEMA
OSC/RRT
WMSSSSSKKKfKSKSSMKWKSWMMWSW
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Function 3: Communications (among Responders)
D Any form(s) of exchanging information or ideas for emergency response with other
entities, either internal or external to the existing organizational structure.
Comment: This aspect of coordination merits special consideration. Different response
organizations typically use different radio frequencies. Therefore, specific
provision must be made for accurate and efficient communication among all
the various organizations during the response itself. Several States have
applied for one "on-scene" command radio frequency that all communities
can use. At a minimum, it may be beneficial to establish radio networks that
will allow for communication among those performing similar functions. The
plan might specify who should be given a radio unit, and who is allowed to
speak on the radio. In order to avoid possible explosion/fire hazards, all com-
munications equipment (including walkie-talkies) should be intrinsically safe.
Function 4: Warning Systems and Emergency Public Notification
D Method for alerting the public
• Title and telephone number of person responsible for alerting the public as soon
as word of the Incident is received
• List of essential data to be passed on (e.g., health hazards, precautions for
personal protection, evacuation routes and shelters, hospitals to be used)
Comment: This section should contain precise information on how sirens or other signals
will be used to alert the public in case of an emergency. This should include
information on what the different signals mean, how to coordinate the use of
sirens, and the geographic area covered by each siren. (If possible, a back-
up procedure should be identified.) While a siren alerts those who hear it, an
emergency broadcast is necessary to provide detailed information about the
emergency and what people should do.
Sample Emergency Broadcast System messages should be prepared with
blank spaces that can be filled in with precise information about the accident.
One sample message should provide fundamental information about the inci-
dent and urge citizens to remain calm and await further information and in-
structions. Another sample message should be for an evacuation. Another
sample message should describe any necessary school evacuations so that
parents will know where their children are. Another sample message should
be prepared to tell citizens to take shelter and inform them of other precau-
tions they may take to protect themselves. The message should clearly iden-
tify those areas in which protective actions are recommended, using familiar
boundaries. Messages might be developed in languages other than English,
if customarily spoken in the area.
This section could be of urgent significance. When life-threatening materials
are released, speed of response is crucial. It is not enough to have planned
for alerting the community; one organization must be assigned the responsi-
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bility of alerting the public as soon as word of the accidental release is re-
ceived. Delay in alerting the public can lead to the loss of life. In addition to
sirens and the Emergency Broadcast System, it may be necessary to use
mobile public address systems and/or house-by-house contacts. In this
case, adequate protection must be provided for persons entering the area to
provide such help.
Function 5: Public Information/Community Relations
D Method to educate the public for possible emergencies
O Method for keeping the public informed
• Provision for one person to serve as liaison to the public
• List of radio and T.V. contacts
Comment: Many communities develop a public information program to educate citizens
about safety procedures during an incident. This program could include
pamphlets; newspaper stories; periodic radio and television announcements;
and programs for schools, hospitals, and homes for the aged.
It is important to provide accurate information to the public in order to pre-
vent panic. Some citizens simply want to know what is happening. Other
citizens may need to be prepared for possible evacuation or they may need
to know what they can do immediately to protect themselves. Because infor-
mation will be needed quickly, radio and television are much more important
than newspapers in most hazardous materials releases. In less urgent
cases, newspaper articles can provide detailed information to enhance public
understanding of accidental spills and procedures for containment and
cleanup. One person should be identified to serve as spokesperson. It is
strongly recommended that the individual identified' have training and experi-
ence in public information, community relations, and/or media relations. The
spokesperson can identify for the media individuals who have specialized
knowledge about the event. The chain of command should include this
spokesperson. Other members of the response team should be trained to
direct all communications and public relations issues to this one person.
Function 6: Resource Management
D List of personnel needed for emergency response [
i
D Training programs, including schedules for training of local emergency response and
medical personnel
D List of vehicles needed for emergency response :
D List of equipment (both heavy equipment and personal protective equipment)
needed for emergency response
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Comment: This section should list the resources that will be needed, and where the
equipment and vehicles are located or can be obtained. A major task in the
planning process is to identify what resources are already available and what
must still be provided. For information on the selection of protective equip-
ment, consult the Occupational Safety and Health Guidance Manual for Haz-
ardous Waste Site Activities prepared by NIOSH, OSHA, USCG, and EPA; and
the EPA/Los Alamos "Guidelines for the Selection of Chemical Protective
Clothing" distributed by the American Conference of Governmental Industrial
Hygienists (Building B-7, 6500 Glynway Ave., Cincinnati, OH 45211).
This section should also address funding for response equipment and per-
sonnel. Many localities are initially overwhelmed by the prospect of providing
ample funding for hazardous materials response activities. In large localities,
each response agency is usually responsible for providing and maintaining
certain equipment and personnel; in such cases, these individual agencies
must devise funding methods, sources, and accounting procedures. In
smaller localities with limited resources, officials frequently develop coopera-
tive agreements with other jurisdictions and/or private industries. Some
communities stipulate in law that the party responsible for an incident should
ultimately pay the cost of handling it.
For a more detailed discussion of response training, consult Chapter 6 of this
guide.
Function 7: Health and Medical
D Provisions for ambulance service
D Provisions for medical treatment
Comment: This section should indicate how medical personnel and emergency medical
services can be summoned. It may be appropriate to establish mutual aid
agreements with nearby communities to provide backup emergency medical
personnel and equipment. The community should determine a policy (e.g.,
triage) for establishing priorities for the use of medical resources during an
emergency. Medical personnel must be made aware of significant chemical
hazards in the community in order to train properly and prepare for possible
incidents. Emergency medical teams and hospital personnel must be trained
in proper methods for decontaminating and treating persons exposed to haz-
ardous chemicals. Planners should include mental health specialists as part
of the team assisting victims of serious incidents. Protective action recom-
mendations for sanitation, water supplies, recovery, and reentry should be
addressed in this section.
Function 8: Response Personnel Safety
D Standard operating procedure for entering and leaving sites
D Accountability for personnel entering and leaving the sites
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D Decontamination procedures
D Recommended safety and health equipment
D Personal safety precautions ;
Comment: Care must be taken to choose equipment that protects the worker from the
hazard present at the site without unnecessarily restricting the capacities of
the worker. Although the emphasis in equipment choices is commonly fo-
cused on protecting the worker from the risks presented by the hazardous
material, impaired vision, restricted movements, or excessive heat can put
the worker at equal risk. After taking these factors into account, the planner
should list the equipment appropriate to various degrees of hazard using the
EPA Levels of Protection (A, B, C, and D). The list should include: the type
of respirator (e.g., self-contained breathing apparatus, supplied air respira-
tor, or air purifying respirator) if needed; the type of clothing that must be
worn; and the equipment needed to protect the head, eyes, face, ears,
hands, arms, and feet. This list can then be used as a base reference for
emergency response. The specific equipment used at a given site will vary
according to the hazard. In addition, the equipment list should be
reevaluated and updated as more information about the site is gathered to
ensure that the appropriate equipment is being used. Responders should
receive ongoing training in the use of safety equipment.
This section can also address liability related to immediate and long term
health hazards to emergency responders. State and local governments may
want to consider insurance coverage and/or the development of waivers for
employees and contractors who may be on site during a hazmat incident.
Function 9: Personal Protection of Citizens
Function 9a: Indoor Protection ;
D Hazard-specific personal protection :
i
Comment: The plan should clearly indicate what protective action should be taken in
especially hazardous situations. Evacuation is sonietimes, but not always,
necessary. (See Function 9b.) For some hazardous materials it is safer to
keep citizens inside with doors and windows closed rather than to evacuate
them. It is perhaps appropiate to go upstairs (or downstairs). Household
items (e.g., wet towels) can provide personal protection for some chemical
hazards. Frequently a plume will move quickly past homes. Modern housing
has adequate air supply to allow residents to remain safely inside for an ex-
tended period of time. Because air circulation systems can easily transport
airborne toxic substances, a warning should be given to shut off all air circu-
lation systems (including heating, air conditioning, clothes dryers, vent fans,
and fire places) both in private and institutional settings.
In order for an indoor protective strategy to be effective, planning and pre-
paredness activities should provide: :
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An emergency management system and decision-making criteria for
determining when an indoor protection strategy should be used;
A system for warning and advising the public;
A system for determining when a cloud has cleared a particular area;
A system for advising people to leave a building at an appropriate time;
and
Public education on the value of indoor protection and on expedient
means to reduce ventilation.
Function 9b: Evacuation Procedures
D Title of person and alternate(s) who can order/recommend an evacuation
D Vulnerable zones where evacuation could be necessary and a method for notifying
these places
D Provisions for a precautionary evacuation
D Methods for controlling traffic flow and providing alternate traffic routes
D Shelter locations and other provisions for evacuations (e.g., special assistance for
hospitals)
D Agreements with nearby jurisdictions to receive evacuees
D Agreements with hospitals outside the local jurisdictions
D Protective shelter for relocated populations
n Reception and care of evacuees
D Re-entry procedures
Comment: Evacuation is the most sweeping response to an accidental release. The
plan should clearly identify under what circumstances evacuation would be
appropriate and necessary. DOT's Emergency Response Guidebook provides
suggested distances for evacuating unprotected people from the scene of an
incident during the initial phase. It is important to distinguish between general
evacuation of the entire area and selective evacuation of a part of the risk
zone. In either case, the plan should identify how people will be moved (i.e.,
by city buses, police cars, private vehicles). Provision must be made for
quickly moving traffic out of the risk zone and also for preventing outside
traffic from entering the risk zone. If schools are located in the risk zone, the
plan must identify the location to which students will be moved in an evacu-
ation and how parents will be notified of this location. Special attention must
also be paid to evacuating hospitals, nursing homes, and homes for the
physically or mentally disabled.
Maps (drawn to the same scale) with evacuation routes and alternatives
clearly identified should be prepared for each risk zone in the area. Maps
should indicate precise routes to another location where special populations
(e.g., from schools, hospitals, nursing homes, homes for the physically or
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mentally disabled) can be taken during an emergency evacuation, and the
methods of transportation during the evacuation.
Consideration of when and how evacuees will return to their homes should be
part of this section.
This section on evacuation should include a description of how other agen-
cies will coordinate with the medical community.
Copies of evacuation procedures should be provided to all appropriate agen-
cies and organizations (e.g., Salvation Army, churches, schools, hospitals)
and could periodically be published in the local newspaper (s).
Function 9c: Other Public Protection Strategies
i
D Relocation
Q Water supply protection ' '
i
D Sewage system protection
Comment: Some hazardous materials incidents may contaminate the soil or water of an
area and pose a chronic threat to people living there. It may be necessary
for people to move out of the area for a substantial period of time until the
area is decontaminated or until natural weathering or decay reduce the haz-
ard. Planning must provide for the quick identification of a threat to the drink-
ing water supply, notification of the public and private system operators, and
warning of the users. Planners should also provide sewage system protec-
tion. A hazardous chemical entering the sewage system can cause serious
and long-term damage. It may be necessary to divert sewage, creating
another public health threat and environmental problems.
Function 10: Fire and Rescue
D Chain of command among firefighters \
D List of available support systems
D List of all tasks for firefighters '
Comment: This section lists all firefighting tasks, as well as the chain of command for
firefighters. This chain of command is especially important if firefighters from
more than one jurisdiction will be involved. Planners should check to see if
firefighting tasks and the chain of command are mandated by their State law.
Firefighters should be trained in proper safety procedures when approaching
a hazardous materials incident. They should have copies of DOT's Emer-
gency Response Guidebook and know how to find shipping manifests in
trucks, trains, and vessels. Specific information about protective equipment
for firefighters should be included here. (See Function 6, "Resource Man-
agement, " and the Occupational Safety and Health Guidance Manual for Haz-
ardous Waste Site Activities.)
i
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This section should also identify any mutual aid or Good Samaritan agree-
ments with neighboring fire departments, hazmat teams, and other support
systems.
Function 11: Law Enforcement
D Chain of command for law enforcement officials
D List of all tasks for law enforcement personnel
Comment: This section lists all the tasks for law enforcement personnel during an emer-
gency response. Planners should check to see if specific law enforcement
tasks are mandated by their State law. Because major emergencies will usu-
ally involve State, county, and local law enforcement personnel, and possibly
the military, a clear chain of command must be determined in advance.
Because they are frequently first on scene, law enforcement officials should
be trained in proper procedures for approaching a hazardous materials inci-
dent. They should have copies of DOT's Emergency Response Guidebook
and know how to find shipping manifests in trucks, trains, and vessels. Spe-
cific information about protective equipment for law enforcement officials
should be included here. (See Function 6, "Resource Management," and
the Occupational Safety and Health Guidance Manual for Hazardous Waste
Site Activities.)
This section should include maps that indicate control points where police
officers should be stationed in order to expedite the movement of responders
toward the scene and of evacuees away from the scene, to restrict unneces-
sary traffic from entering the scene, and to control the possible spread of
contamination.
W««/^"W**VAW.W*^'AVA^W.V.W
Function 12: Ongoing Incident Assessment
D Field monitoring teams
D Provision for environmental assessment, biological monitoring, and contamination
surveys
D Food/water controls
Comment: After the notification that a release has occurred, it is crucial to monitor the
release and assess its impact, both on and off site. A detailed log of all
sampling results should be maintained. Health officials should be kept in-
formed of the situation. Often the facility at which the release has occurred
will have the best equipment for this purpose.
This section should describe who is responsible to monitor the size, concen-
tration, and movement of leaks, spills, and releases, and how they will do
their work. Decisions about response personnel safety, citizen protection
(whether indoor or through evacuation), and the use of food and water in the
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area will depend upon an accurate assessment of spill or plume movement
and concentration. Similarly, decisions about containment and cleanup de-
pend upon monitoring data.
Function 13: Human Services
D List of agencies providing human services
D List of human services tasks
Comment: This section should coordinate the activities of organizations such as the Red
Cross, Salvation Army, local church groups, and others that will help people
during a hazardous materials emergency. These services are frequently per-
formed by volunteers. Advance coordination is essential to ensure the most
efficient use of limited resources.
Function 14: Public Works
a List of all tasks for public works personnel
Comment: This section lists all public works tasks during an emergency response. Pub-
lic works officials should also be familiar with Plan Section D ("Containment
and Cleanup"). :
Function 15: Others
!
Comment: If the preceding list of functions does not adequately cover the various tasks
to be performed during emergency responses, additional response functions
can be developed.
tifffffffffffi/iffffifiMfififM^^
i
Planning Element D: Containment and Cleanup
Planning Element D.1: Techniques for Spill Containment and Cleanup
O Containment and mitigation actions
D Cleanup methods
D Restoration of the surrounding environment : . ..
Comment: Local resppnders will typically emphasize the containment and stabilization of
an incident; State regulatory agencies can focus on cleanup details. Federal
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RRT agencies can provide assistance during the cleanup process. It is the
releaser's legal and financial responsibility to clean up and minimize the risk
to the health of the general public and workers that are involved. The Federal
OSC or other government officials should monitor the responsible party
cleanup activities.
A clear and succinct list of appropriate containment and cleanup counter-
measures should be prepared for each hazardous material present in the
community in significant quantities. This section should be coordinated with
the section on "Response Personnel Safety" so that response teams are
subjected to minimal danger. Planners should concentrate on the techniques
that are applicable to the hazardous materials and terrain of their area. It
may be helpful to include sketches and details on how cleanup should occur
for certain areas where spills are more likely.
It is important to determine whether a fire should be extinguished or allowed
to burn. Water used in firefighting could become contaminated and then
would need to be contained or possibly treated. In addition, some materials
may be water-reactive and pose a greater hazard when in contact with
water. Some vapors may condense into pools of liquid that must be con-
tained and removed. Accumulated pools may be recovered with appropriate
pumps, hoses, and storage containers. Various foams may be used to re-
duce vapor generation rates. Water sprays or fog may be applied at down-
wind points away from "cold" pools to absorb vapors and/or accelerate their
dispersal in the atmosphere. (Sprays and fog might not reduce an explosive
atmosphere.) Volatile liquids might be diluted or neutralized.
If a toxic vapor comes to the ground on crops, on playgrounds, in drinking
water, or other places where humans are likely to be affected by it, the area
should be tested for contamination. Appropriate steps must be taken if ani-
mals (including fish and birds) that may become part of the human food
chain are in contact with a hazardous material. It is important to identify in
advance what instruments and methods can be used to detect the material in
question.
Restoration of the area is a long-range project, but general restoration steps
should appear in the plan. Specific consideration should be given to the
mitigation of damages to the environment.
Planning Element D.2: Resources for Cleanup and Disposal
D Cleanup/disposal contractors and services provided
D Cleanup material and equipment
D Communications equipment
D Provision for long-term site control during extended cleanups
D Emergency transportation (e.g., aircraft, four-wheel-drive vehicles, boats)
D Cleanup personnel
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D Personal protective equipment
D Approved disposal sites
Comment: This section is similar to the yellow pages of the telephone book. It provides
plan users with the following important information:
• What types of resources are available (public and private);
• How much is stockpiled;
• Where it is located (address and telephone number); and
• What steps are necessary to obtain the resources.
Organizations that may have resources for use during a hazardous materials
incident include: '.
• Public agencies (e.g., fire, police, public works, public health, agricul-
ture, fish and game); :
• Industry (e.g., chemical producers, transporters, storers, associations;
spill cleanup contractors; construction companies);
" I
• Spill/equipment cooperatives; and ,
• Volunteer groups (ham radio operators, four-wheel-drive vehicle
clubs).
!
Resource availability will change with time, so keep this section of the plan
up-to-date. |
Hazardous materials disposal may exceed the capabilities of smaller cities
and towns; in such cases, the plan should indicate the appropriate State and/
or Federal agency that is responsible for making!decisions regarding dis-
posal, i
i
i
Disposal of hazardous materials or wastes is controlled by a number of Fed-
eral and State laws and regulations. Both CERCLA and RCRA regulate waste
disposal and it is important that this section reflect the requirements of these
regulations for on-site disposal, transportation, and off-site disposal. The
plan should include an updated list of RCRA disposal facilities for possible use
during an incident.
Many States have their own regulations regarding transport and ultimate dis-
posal of hazardous waste. Usually such regulations are similar and substan-
tially equal to Federal regulations. Contact appropriate State agency offices
for information on State requirements for hazardous waste disposal.
i
twi..l...l.f....iv^
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Planning Element E: Documentation and Investigative Follow-Up
n List of required reports
D Reasons for requiring the reports
D Format for reports
D Methods for determining whether the response mechanism worked properly
D Provision for cost recovery
Comment: This section indicates what information should be gathered about the release
and the response operation. Key response personnel could be instructed to
maintain an accurate log of their activities. Actual response costs should be
documented in order to facilitate cost recovery.
It is also important to identify who is responsible for the post-incident investi-
gation to discover quickly the exact circumstances and cause of the release.
Critiques of real incidents, if handled tactfully, allow improvements to be
made based on actual experience. The documentation described above
should help this investigation determine if response operations were effec-
tive, whether the emergency plan should be amended, and what follow-up
responder and public training programs are needed.
Planning Element F: Procedures for Testing and Updating Plan
Planning Element F.1: Testing the Plan
D Provision for regular tabletop, functional, and full-scale exercises
Comment: Exercises or drills are important tools in keeping a plan functionally up-to-
date. These are simulated accidental releases where emergency response
personnel act out their duties. The exercises can be tabletop and/or they
can be realistic enough so that equipment is deployed, communication gear
is tested, and "victims" are sent to hospitals with simulated injuries. Plan-
ners should work with local industry and the private medical community when
conducting simulation exercises, and they should provide for drills that com-
ply with State and local legal requirements concerning the content and fre-
quency of drills. After the plan is tested, it should be revised and retested
until the planning team is confident that the plan is ready. The public should
be involved in or at least informed of these exercises. FEMA, EPA, and CMA
provide guidance on simulation exercises through their training programs
complementing this guide.
This section should specify:
(1) The organization in charge of the exercise;
(2) The types of exercises;
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(3) The frequency of exercises; and
(4) A procedure for evaluating performance, making changes to plans, and
correcting identified deficiencies in response capabilities as necessary.
(See Chapter 6 of this guide.)
Planning Element F.2: Updating the Plan
D Title and organization of responsible person (s) !
D Change notification procedures
O How often the plan should be audited and what mechanisms will be used to change
the plan ;
Comment: Responsibility should be delegated to someone to pnake sure that the plan is
updated frequently and that all plan holders are informed of the changes.
Notification of changes should be by written memorandum or letter; the
changes should be recorded in the RECORD OF AMENDMENTS page at the
front of the completed plan. Changes should be consecutively numbered for
ease of tracking and accounting. I
Following are examples of information that must' regularly be checked for
accuracy: ;
i
1
(1) Identity and phone numbers of response personnel
(2) Name, quantity, properties, and location of hazardous materials in the
community. (If new hazardous materials are made, used, stored, or trans-
ported in the community, revise the plan as needed.)
(3) Facility maps
(4) Transportation routes
(5) Emergency services available
(6) Resource availability ;
This topic is considered in greater detail in Chapter 6 of this guidance.
Planning Element G: Hazards Analysis (Summary)
a Identification of hazards i
D Analysis of vulnerability i
D Analysis of risk ;
Comment: This analysis is a crucial aspect of the planning process. It consists of deter-
mining where hazards are likely to exist, what places would most likely be
adversely affected, what hazardous materials could be involved, and what
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conditions might exist during a spill or release. To prepare a hazards analy-
sis, consult Chapter 3 of this guide, EPA's CEPP technical guidance, and
DOT'S Community Teamwork and Lessons Learned. Ask Federal offices
(listed in Appendix F) for information about available computer programs to
assist in a hazards analysis.
Individual data sheets and maps for each facility and transportation routes of
interest could be included in this section. Similar data could be included for
recurrent shipments of hazardous materials through the area. This section
will also assess the probability of damage and/or injury. In communities with a
great deal of hazardous materials activity, the hazards analysis will be too
massive to include in the emergency plan. In that case, all significant details
should be summarized here.
Planning Element H: References
Planning Element H.1: Laboratory, Consultant,
and Other Technical Support Resources
D Telephone directory of technical support services
• Laboratories (environmental and public health)
• Private consultants
• Colleges or universities (chemistry departments and special courses)
• Local chemical plants
Comment: This section should identify the various groups capable of providing technical
support and the specific person to be contacted. Medical and environmental
laboratory resources to assess the impact of the most probable materials
that could be released should be identified. Note should be made about the
ability of these laboratories to provide rapid analysis. These technical experts
can provide advice during a disaster and also be of great service during the
development of this plan. For this reason, one of the first planning steps
should be gathering information for this section.
Planning Element H.2: Technical Library
D List of references, their location, and their availablility
• General planning references
• Specific references for hazardous materials
• Technical references and methods for using national data bases
• Maps
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Comment: Industry sources can provide many specific publications dealing with hazard-
ous materials. This section of the plan will list those published resources that
are actually available in the community. Also list &ny maps (e.g., of facili-
ties, transportation routes) that Will aid in the response to an accidental spill
or release.
i
The list of technical references in Appendix E could'be helpful. Regional Fed-
eral offices can also be contacted (see Appendix F).
It is important for planners to acquire, understand,land be able to use avail-
able hazardous materials data bases, including electronic data bases avail-
able from commercial and government sources, i Planning guides such as
DOT'S Community Teamwork, CMA's CAER program, EPA's CEPP technical
guidance, and this guide should also be available locally.
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6. Plan Appraisal and Continuing Planning
6.1 Introduction
Any emergency plan must be evaluated
and kept up-to-date through the review
of actual responses, simulation exer-
cises, and regular collection of new
data. Effective emergency preparedness
requires periodic review and evaluation,
and the necessary effort must be sus-
tained at the community level. Plans
should reflect any recent changes in: the
economy, land use, permit waivers, avail-
able technology, response capabilities,
hazardous materials present, Federal and
State laws, local laws and ordinances,
road configurations, population change,
emergency telephone numbers, and facil-
ity location. This chapter describes key
aspects of appraisal and provides specific
guidance for maintaining an updated haz-
ardous materials emergency plan.
6.2 Plan Review and Approval
Plan review and approval are critically im-
portant responsibilities of the planning
team. This section discusses the various
means by which a plan can be reviewed
thoroughly and systematically.
6.2.1. Internal Review
The planning team, after drafting the plan,
should conduct an internal review of the
plan. It is not sufficient merely to read
over the plan for clarity or to search for
errors. The plan should also be assessed
for adequacy and completeness. Appen-
dix D is an adaptation of criteria developed
by the National Response Team that in-
cludes questions useful in appraising
emergency plans. Individual planning
team members can use these questions
to conduct self review of their own work
and the team can assign a committee to
review the total plan. In the case of a haz-
ardous materials appendix (or appendi-
ces) to a multi-hazard EOP, the team will
have to review the basic EOP as well as
the functional annexes to obtain an overall
assessment of content. Once the team
accomplishes this internal review the plan
should be revised in preparation for exter-
nal review.
6.2.2. External Review
External review legitimizes the authority
and fosters community acceptance of the
plan. The review process should involve
elements of peer review, upper level re-
view, and community input. The planning
team must devise a process to receive,
review, and respond to comments from
external reviewers.
^- A. Peer Review
Peer review entails finding qualified indi-
viduals who can provide objective reviews
of the plan. Individuals with qualifications
similar to those considered for inclusion
on the planning team should be selected
as peer reviewers. Examples of appropri-
ate individuals include:
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D The safety or environmental en-
gineer in a local industry;
D Responsible authorities from
other political jurisdictions (e.g.,
fire chief, police, environmental
and/or health officers);
D A local college professor familiar
with hazardous materials re-
sponse operations; and
D A concerned citizen's group,
such as the League of Women
Voters, that provides a high level
of objectivity along with the ap-
propriate environmental aware-
ness.
Exhibit 2 (Chapter 2, page 13) presents a
comprehensive list of potential peer re-
viewers. Those selected as peer review-
ers should use the criteria contained in
Appendix D to develop their assessments
of the plan.
^- B. Upper Level Review
Upper level review involves submitting the
plan to an individual or group with over-
sight authority or responsibility for the
plan. Upper level review should take
place after peer review and modification
of the plan.
>• C. Community Input
Community involvement is vital to success
throughout the planning process. At the
plan appraisal stage, such involvement
greatly facilitates formal acceptance of
the plan by the community. Approaches
that can be used include:
D Community workshops with
short presentations by planning
team members followed by a
question-and-answer period;
D Publication of notice "for com-
ment" in local newspapers, of-
fering interested individuals and
groups an opportunity to express
their views in writing;
D Public meetings at which citi-
zens can submit oral and written
comments;
D Invited reviews by key interest
groups that provide an opportu-
nity for direct participation for
such groups that are not repre-
sented on the planning team;
and
D Advisory councils composed of
a relatively large number of in-
terested parties that can inde-
pendently review and comment
on the planning team's efforts.
These activities! do more than encourage
community consensus building. Commu-
nity outreach at this stage in the process
also improves the soundness of the plan
by increased public input and expands
public understanding of the plan and thus
the effectiveness of the emergency re-
sponse to a hazardous materials incident.
^- D. State/Federal Review
After local review and testing through ex-
ercises, a community may want to re-
quest review of the plan by State and/or
Federal officials. Such a review will de-
pend upon the availability of staff re-
sources. Planning committees set up in
accordance with Title III of SARA are to
submit a copy 'of the emergency plan to
the State emergency response commis-
sion for review!to ensure coordination of
the plan with emergency plans of other
planning districts. Federal Regional Re-
sponse Teams .may review and comment
upon an emergency plan, at the request
of a local emergency planning committee.
FEMA Regional offices review FEMA-
funded multi-hazard EOPs using criteria in
CPG 1-8A. ;
6.2.3. Plan Approval
The planning team should identify and
comply with any local or State require-
ments for formal plan approval. It may be
necessary for local officials to enact legis-
lation that gives legal recognition to the
emergency plan.
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6.3 Keeping the Plan Up-to-Date
All emergency plans become outdated
because of social, economic, and envi-
ronmental changes. Keeping the plan
current is a difficult task, but can be
achieved by scheduling reviews regularly.
As noted in Chapter 5, the plan itself
should indicate who is responsible for
keeping it up-to-date. Outdated informa-
tion should be replaced, and the results of
appraisal exercises should be incorpo-
rated into the plan. The following tech-
niques will aid in keeping abreast of rele-
vant changes:
D Establish a regular review pe-
riod, preferably every six
months, but at least annually.
(Title III of SARA requires an an-
nual review.)
D Test the plan through regularly
scheduled exercises (at least
annually). This testing should in-
clude debriefing after the exer-
cises whenever gaps in prepar-
edness and response capabili-
ties are identified.
D Publish a notice and announce a
comment period for plan review
and revisions.
D Maintain a list of individuals,
agencies, and organizations that
will be interested in participating
in the review process.
D Make one reliable organization
responsible for coordination of
the review and overall
stewardship of the plan. Use of
the planning team in this role is
recommended, but may not be
a viable option due to time avail-
ability constraints of team mem-
bers.
n Require immediate reporting by
any facility of an increase in
quantities of hazardous materi-
als dealt with in the emergency
plan, and require review and re-
vision of plan if needed in re-
sponse to such new information.
D Include a "Record of Amend-
ments and Changes" sheet in
the front section of the plan to
help users of the plan stay
abreast of all plan modifications.
D Include a "When and Where to
Report Changes" notice in the
plan and a request for holders of
the plan to report any changes
or suggested revisions to the re-
sponsible organization at the ap-
propriate time.
D Make any sections of the plan
that are subject to frequent
changes either easily replace-
able (e.g., looseleaf, separate
appendix), or provide blank
space (double- or triple-spaced
typing) so that old material may
be crossed out and new data
easily written in. This applies
particularly to telephone rosters
and resource and equipment
listings.
The organization responsible for review
should do the following:
D Maintain a list of plan holders,
based on the original distribution
list, plus any new copies made
or distributed. It is advisable to
send out a periodic request to
departments/branches showing
who is on the distribution list and
asking for any additions or cor-
rections.
n Check all telephone numbers,
persons named with particular
responsibilities, and equipment
Page 69
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locations and availability. In ad-
dition, ask departments and
agencies to review sections of
the plan defining their responsi-
bilities and actions.
D Distribute changes. Changes
should be consecutively num-
bered for ease of tracking. Be
specific, e.g., "Replace page
with the attached new page
.," or "Cross out on page
and write in the following"
(new phone number, name, lo-
cation, etc.). Any key change
(new emergency phone number,
change in equipment availability,
etc.) should be distributed as
soon as it occurs. Do not wait
for the regular review period to
notify plan holders.
D If possible, the use of electronic
word processing is recom-
D
D
D
mended because it facilitates
changing the plan. After a sig-
nificant number of individual
changes, the entire plan should
be redistributed to ensure com-
pleteness.
If practical, request an acknow-
ledgement of changes from
those: who have received
changes. The best way to do
this is to include a self-
addressed postcard to be re-
turned with acknowledgement
(e.g.,; "I have received and en-
tered changes dated . Signed
Attend any plan critique meet-
ings and issue changes as may
be required.
i
Integrate changes with other re-
lated plans.
6.4 Continuing Planning
In addition to the periodic updates de-
scribed above, exercises, incident re-
views, and training are necessary to en-
sure current and effective planning.
6.4.1 Exercises
The plan should also be evaluated through
exercises to see if its required activities
are effective in practice and if the evalu-
ation would reveal more efficient ways of
responding to a real emergency. As
noted in Chapter 5, the plan itself should
indicate who is responsible for conducting
exercises. Simulations can be full-scale,
functional, or tabletop exercises.
A full-scale exercise is a mock emer-
gency in which the response organizations
that would be involved in an actual emer-
gency perform the actions they would
take in the emergency. These simulations
may focus on limited objectives (e.g.,
testing the capability of local hospitals to
handle relocation problems). The respon-
sible environmental, public safety, and
health agencies simulate, as realistically
as possible, notification, hazards identifi-
cation and analysis, command structure,
command post [staging, communications,
health care, containment, evacuation of
affected areas, cleanup, and documenta-
tion. Responders use the protective gear,
radios, and response equipment and act
as they would in a real incident. These
multi-agency exercises provide a clearer
understanding of the roles and resources
of each responder.
A functional exercise involves testing or
evaluating the jcapability of individual or
multiple functions, or activities within a
function. ;
A low-cost, valuable version of an exer-
cise is the staging of a tabletop exercise.
In this exercise; each agency representa-
tive describes and acts out what he or she
Page 70
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would do at each step of the response un-
der the circumstances given.
Exercises are most beneficial when fol-
lowed by a meeting of all participants to
critique the performance of those involved
and the strengths and weaknesses of the
plan's operation. The use of an outside
reviewer, free of local biases, is desir-
able. The emergency plan should be
amended according to the lessons
learned. Provisions should be made to
follow up exercises to see that identified
deficiencies are corrected.
Communities that want help in preparing
and conducting exercises should consult
FEMA's four-volume "Exercise Design
Course," which includes sample hazard-
ous materials exercises. CMA's Commu-
nity Emergency Response Exercise Hand-
book is also helpful. CM A describes four
types of exercises: tabletop, emergency
operations simulation, drill, and field exer-
cise.
6.4.2 Incident Review
When a hazardous materials incident does
occur, a review or critique of the incident
is a means of evaluating the plan's effec-
tiveness. Recommendations for conduct-
ing an incident review are:
D Assign responsibility for incident
review to the same organization
that is responsible for plan up-
date, for example, the planning
team.
D Conduct the review only after
the emergency is under control
and sufficient time has passed to
allow emergency respondents to
be objective about the incident.
D Use questionnaires, telephone
interviews, or personal inter-
views to obtain comments and
suggestions from emergency re-
spondents. Follow-up on non-
respondents.
D Identify plan and response defi-
ciencies: items that were over-
looked, improperly identified, or
were not effective.
D Convene the planning team to
review comments and make ap-
propriate plan changes.
D Revise the plan as necessary.
Communicate personal or de-
partmental deficiencies infor-
mally to the appropriate person
or department. Follow up to see
that deficiencies are corrected.
6.4.3 Training
Training courses can help with continuing
planning by sharpening response person-
nel skills, presenting up-to-date ideas/
techniques, and promoting contact with
other people involved in emergency re-
sponse. Everyone who occupies a posi-
tion that is identified in the plan must have
appropriate training. This applies to per-
sons at all levels who serve to coordinate
or have responsibilities under the plan,
both those directly and indirectly involved
at the scene of an incident. One should
not assume that a physician in the emer-
gency room or a professional environmen-
talist is specifically trained to perform his/
her assigned mission during an emer-
gency.
The training could be a short briefing on
specific roles and responsibilities, or a
seminar on the plan or on emergency
planning and response in general. How-
ever the training is conducted, it should
convey a full appreciation of the impor-
tance of each role and the effect that
each person has on implementing an ef-
fective emergency response.
Training is available from a variety of
sources in the public and private sectors.
At the Federal level, EPA, FEMA, OSHA,
DOT/RSPA and the USCG offer hazardous
materials training. (In some cases, there
are limits on attendance in these
courses.) FEMA, EPA, and other NRT
agencies cooperatively offer the inter-
agency "train-the-trainer" course, Haz-
F'age 71
-------
ardous Materials Contingency Planning, at
Emmitsburg, MD and in the field.
Title III of SARA authorizes Federal funding
for training. Communities seeking training
assistance should consult appropriate
State agencies. States may consult with
the RRT and the various Federal Regional
and district offices. (See Appendix F.)
In addition to government agencies, con-
sult universities or community colleges
(especially any fire science curriculum
courses), industry associations, special
interest groups, and the private sector
(fixed facilities, shippers, and carriers).
Many training films and slide presentations
can be borrowed or rented at little cost.
Many chemical companies and carriers
provide some level of training free.
The Chemical Manufacturers Association
has a lending library of audio-visual train-
ing aids for use by personnel who respond
to emergencies involving chemicals. The
training aids are available on a loan basis
at no charge to emergency response per-
sonnel and the public sector.
Training aids can also be purchased from:
National Chemical Response and
Information Center
Chemical Manufacturers Association
2501 M Street, N.W.
Washington, DC 20037
In addition to ; classroom training, re-
sponse personnel will need hands-on ex-
perience with equipment to be used dur-
ing an emergency.
Communities should provide for refresher
training of response personnel. It is not
sufficient to attend training only once.
Training must be carried out on a continu-
ing basis to ensure currency and capabil-
ity. Some communities have found it ef-
fective to hold ithis refresher training in
conjunction withi an exercise.
The NRT, through its member agencies, is
developing a strategy to address issues
related to emergency preparedness and
response for hazardous materials inci-
dents. The training strategy includes: (1)
improved coordination of available Federal
training programs and courses; (2) shar-
ing information about available training,
and lessons learned from responses to re-
cent hazardous' materials incidents; (3)
the increased use of exercises as a train-
ing method; (4) the revision of existing
core courses, and the development of
any needed new core courses that pre-
pare responders to do the actual tasks ex-
pected in their own communities; and (5)
decentralizing the delivery of training so
that it is more easily available to respond-
ers. Further information about this train-
ing strategy can be obtained from EPA or
FEMA offices in Washington, DC (see
page F-1 for addresses).
Page 72
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APPENDIX A
IMPLEMENTING TITLE 111: EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW:
SUPERFUND AMENDMENTS AND REAUTHORIZATION
ACT OF 1986
tions are interrelated in a way that unifies
the emergency planning and community
right-to-know provisions of Title III. (See
Exhibit 6.)
This appendix includes a detailed sum-
mary of Title HI of SARA. The material
printed in italics indicates how informa-
tion generated by compliance with Title
III can be of use to local emergency
planning committees. Exhibit 5 is a list
of key dates relative to Title HI imple-
mentation. Exhibit 6 is a graphic repre-
sentation of the flow of information re-
quired by Title III. Exhibit 7 summa-
rizes ways in which Title HI information
can be used by local emergency planning
committees. Exhibit 8 identifies various
lists of chemicals mentioned in Title HI
and indicates the purpose (s) of each
list.
On October 17, 1986, the President
signed the "Superfund Amendments and
Reauthorization Act of 1986" (SARA) into
law. One part of the new SARA provisions
is Title III: the "Emergency Planning and
Community Right-to-Know Act of 1986."
Title III establishes requirements for Fed-
eral, State, and local governments, and
industry regarding emergency planning
and community right-to-know reporting
on hazardous chemicals. This legislation
builds upon the Environmental Protection
Agency's (EPA's) Chemical Emergency
Preparedness Program (CEPP) and nu-
merous State and local programs aimed
at helping communities to meet their re-
sponsibilities in regard to potential chemi-
cal emergencies.
Title III has four major sections: emer-
gency planning (§ 301-303), emergency
notification (§ 304), community right-to-
know reporting requirements (§ 311,
312), and toxic chemical release reporting
— emissions inventory (§ 313). The sec-
In addition to increasing the public's
knowledge and access to information on
the presence of hazardous chemicals in
their communities and releases of these
chemicals into the environment, the
community right-to-know provisions of
Title HI will be important in preparing
emergency plans.
This appendix includes a summary of
these four major sections, followed by a
discussion of other Title III topics of inter-
est to emergency planners.
Sections 301-303:
Planning
Emergency
The emergency planning sections are de-
signed to develop State and local govern-
ment emergency preparedness and re-
sponse capabilities through better coordi-
nation and planning, especially at the local
level.
Title III requires that the Governor of each
State designate a State emergency re-
sponse commission (SERC) by April 17,
1987. While existing State organizations
can be designated as the SERC, the com-
mission should have broad-based repre-
sentation. Public agencies and depart-
ments concerned with issues relating to
the environment, natural resources,
emergency management, public health,
occupational safety, and transportation all
have important roles in Title III activities.
Page A-l
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Various public and private sector groups
and associations with interest and exper-
tise in Title III issues can also be included
on the SERC.
The SERC must designate local emer-
gency planning districts by July 17, 1987,
and appoint local emergency planning
committees (LEPCs) within one month af-
ter a district is designated. The SERC is
responsible for supervising and coordinat-
ing the activities of the LEPCs, for estab-
lishing procedures for receiving and proc-
essing public requests for information col-
lected under other sections of Title III, and
for reviewing local emergency plans.
The LEPC must include elected State and
local officials, police, fire, civil defense,
public health professionals, environ-
mental, hospital, and transportation offi-
cials as well as representatives of facili-
ties, community groups, and the media.
Interested persons may petition the SERC
to modify the membership of an LEPC.
No later than September 17, 1987, facili-
ties subject to the emergency planning re-
quirements must notify the LEPC of a rep-
resentative who will participate in the plan-
ning process as a facility emergency co-
ordinator.
Facility emergency coordinators will be
of great service to LEPCs. For exam-
ple, they can provide technical assis-
tance, an understanding of facility re-
sponse procedures, information about
chemicals and their potential effects on
nearby persons and the environment,
and response training opportunities.
CEPP experience revealed that, as a re-
sult of CMA's CAER initiative, there al-
ready exist a large number of plant
managers and other facility personnel
who want to cooperate with local com-
munity planners.
The LEPC must establish rules, give public
notice of its activities, and establish pro-
cedures for handling public requests for
information.
The LEPC's primary responsibility will be
to develop an emergency response plan
by October 17, 1988. In developing this
plan, the local committee will evaluate
available resources for preparing for and
responding to a potential chemical acci-
dent. The plan must include:
• Identification of facilities and ex-
tremely ' hazardous substances
transportation routes;
!
• Emergency response procedures,
on site and off site;
!
• Designation of a community coordi-
nator and, facility coordinator(s) to
implement the plan;
• Emergency notification procedures;
• Methods for determining the occur-
rence of a release and the probable
affected area and population;
• Description of community and indus-
try emergency equipment and facili-
ties, and the identity of persons re-
sponsible for them;
• Evacuation plans;
• Description and schedules of a train-
ing program for emergency re-
sponse to chemical emergencies;
and i
i '
• Methods and schedules for exercis-
ing emergency response plans.
To assist the LEPC in preparing and re-
viewing plans, Congress required the Na-
tional Response Team (NRT), composed
of 14 Federal agencies with emergency
preparedness and response responsibili-
ties, to publish: guidance on emergency
planning. This Hazardous Materials Emer-
gency Planning ; Guide is being published
by the NRT to fulfill this requirement.
Page A-2
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The emergency plan must be reviewed by
the SERC upon completion and reviewed
annually by the LEPC. The Regional Re-
sponse Teams (RRTs), composed of Fed-
eral Regional officials and State represen-
tatives, may review the plans and provide
assistance if the LEPC so requests.
The emergency planning activities of the
LEPC and facilities should initially be fo-
cused on, but not limited to, the ex-
tremely hazardous substances published
as an interim final rule in the November
17, 1986, Federal Register. The list in-
cluded the threshold planning quantity
(TPQ) for each substance. EPA can re-
vise the list and TPQs but must take into
account the toxicity, reactivity, volatility,
dispersability, combustibility, or flamma-
bility of a substance. Consult EPA Re-
gional offices for a copy of the Title III
(Section 302) list of extremely hazardous
substances.
Any facility that produces, uses, or stores
any of the listed chemicals in a quantity
greater than the TPQ must meet all emer-
gency planning requirements. In addition,
the SERC or the Governor can designate
additional facilities, after public comment,
to be subject to these requirements. By
May 17, 1987, facilities must notify the
SERC that they are subject to these re-
quirements. If, after that time, a facility
first begins to produce, use, or store an
extremely hazardous substance in an
amount exceeding the threshold planning
quantity, it must notify the SERC and LEPC
within 60 days.
Each SERC must notify EPA Regional of-
fices of all facilities subject to Title III plan-
ning requirements.
In order to complete information on
many sections of the emergency plan,
the LEPC will require data from the fa-
cilities covered under the plan. Title HI
provides authority for the LEPC to se-
cure from a facility information that it
needs for emergency planning and re-
sponse. This is provided by Section 303
(d) (3), which states that:
"Upon request from the emergency plan-
ning committee, the owner or operator
of the facility shall promptly provide in-
formation to such committee necessary
for developing and implementing the
emergency plan."
Within the trade secret restrictions con-
tained in Section 322, LEPCs should be
able to use this authority to secure from
any facility subject to the planning pro-
visions of the law information needed
for such mandatory plan contents as:
facility equipment and emergency re-
sponse capabilities, facility emergency
response personnel, and facility evacu-
ation plans.
Some of the facilities subject to Section
302 planning requirements may not be
subject to Sections 311-12 reporting re-
quirements, which are currently limited
to manufacturers and importers in SIC
codes 20-39. LEPCs may use Section
303 (d) (3) authority to gain information
such as name(s), MSDSs, and quantity
and location of chemicals present at fa-
cilities subject to Section 302.
Section 304: Emergency Notification
If a facility produces, uses, or stores one
or more hazardous chemical, it must im-
mediately notify the LEPC and the SERC if
there is a release of a listed hazardous
substance that exceeds the reportable
quantity for that substance. Substances
subject to this notification requirement in-
clude substances on the list of extremely
hazardous substances published in the
Federal Register on November 17, 1986,
and substances subject to the emergency
notification requirements of CERCLA Sec-
tion 103 (a).
Page A-3
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mgig^^
Information included in this initial noti-
fication (as well as the additional infor-
mation in the follow-up written notice
described below) can be used by the
LEPC to prepare and/or revise the
emergency plan. This information
should be especially helpful in meeting
the requirement to list methods for de-
termining if a release has occurred and
identifying the area and population most
likely to be affected.
The Initial notification of a release can be
by telephone, radio, or in person. Emer-
gency notification requirements involving
transportation incidents may be satisfied
by dialing 911 or, in the absence of a 911
emergency number, calling the operator.
This emergency notification needs to in-
clude: the chemical name; an indication
of whether the substance is an extremely
hazardous substance; an estimate of the
quantity released into the environment;
the time and duration of the release; the
medium into which the release occurred;
any known or anticipated acute or chronic
health risks associated with the emer-
gency and, where appropriate, advice re-
garding medical attention necessary for
exposed individuals; proper precautions,
such as evacuation; and the name and
telephone number of a contact person.
Section 304 also requires a follow-up writ-
ten emergency notice after the release.
The follow-up notice or notices shall up-
date information included in the initial no-
tice and provide additional information on
actual response actions taken, any known
or anticipated data on chronic health risks
associated with the release, and advice
regarding medical attention necessary for
exposed individuals.
The requirement for emergency notifica-
tion comes into effect with the establish-
ment of the SERC and LEPC. If no SERC
is established by April 17, 1987, the Gov-
ernor becomes the SERC and notification
should be made to him/her. If no LEPC is
established by August 17, 1987, local no-
tification must be made to the appropriate
local emergency response personnel,
such as the fire department.
Sections 311-312: Community Right-
to-Know Reporting Requirements
As noted above. Section 303 (d) (3) gives
LEPCs access ,to information from fa-
cilities subject to Title HI planning re-
quirements. Sections 3*11-12 provide
information about the nature, quantity,
and location of chemicals at many fa-
cilities not subject to the Section
303 (d) (3) requirement. For this rea-
son, LEPCs will find Sections 311-12
information especially helpful when pre-
paring a comprehensive plan for the en-
tire planning district.
There are two community right-to-know
reporting requirements. Section 311 re-
quires a facility which must prepare or
have available material safety data sheets
(MSDSs) under the Occupational .Safety
and Health Administration (OSHA) hazard
communications regulations to submit
either copies of its MSDSs or a list of
MSDS chemicals to the LEPC, the SERC,
and the local fire department. Currently,
only facilities in Standard Industrial Classi-
fication (SIC) Codes 20-39 (manufactur-
ers and importers) are subject to these
OSHA regulations.
The initial submission of the MSDSs or list
is required no' later than October 17,
1987, or 3 months after the facility is
required to prepare or have available an
MSDS under OSHA regulations. A revised
MSDS must be provided to update an
MSDS which was originally submitted if
significant new . information regarding a
chemical is discovered.
EPA encourages LEPCs and fire depart-
ments seriously to consider contacting
Page A-4
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facilities prior to the deadline of Octo-
ber 17, 1987 to request the submission
of lists rather than MSDS forms. In
communities with a large number of
facilities, handling large numbers of
chemicals, and in communities with
limited capabilities to store and manage
the MSDSs, the list of MSDS chemicals
from the facility would be more useful
than the forms themselves, and likely to
be more easily produced.
LEPCs also have the option of using the
chemical names provided to develop
additional data on each of the
chemicals, using a variety of data
sources, including several on-line data
bases maintained by agencies of the
Federal government.
Specific MSDSs could be requested on
chemicals that are of particular con-
cern. In general every MSDS will
provide the LEPC and the fire
departments in each community with the
following information on each of the
chemicals covered:
• The chemical name;
• Its basic characteristics, for example:
o toxicity, corrosivity, reactivity,
o known health effects, including
chronic effects from exposure,
o basic precautions in handling,
storage, and use,
o basic countermeasures to take in
the event of a fire, explosion, leak,
and
o basic protective equipment to
minimize exposure.
In any case, these data should be useful
for the planning to be accomplished by
the LEPC and first responders,
especially fire departments and hazmat
teams. Both hazards analysis and the
development of emergency counter-
measures should be facilitated by the
availability of MSDS information.
If the facility owner or operator chooses to
submit a list of MSDS chemicals, the list
must include the chemical name or
common name of each substance and
any hazardous component as provided on
the MSDS. This list must be organized in
categories of health and physical hazards
as set forth in OSHA regulations or as
modified by EPA.
If a list is submitted, the facility must pro-
vide the MSDS for any chemical on the list
upon the request of the LEPC. Under
Section 311, EPA may establish threshold
quantities for hazardous chemicals below
which no facility must report.
The reporting requirement of Section 312
requires facilities to submit an emergency
and hazardous chemical inventory form to
the LEPC, the SERC, and the local fire
department. The hazardous chemicals
covered by Section 312 are the same
chemicals for which facilities are required
to submit MSDS forms or the list for
Section 311.
Under Sections 311-12, EPA may
establish threshold quantities for
hazardous chemicals below which no
facility is subject to this requirement. See
the proposed rule in the January 27, 1987
Federal Register. The Final Rule will be
published before October 1987.
The inventory form incorporates a two-tier
approach. Under Tier I, facilities must
submit the following aggregate
information for each applicable OSHA
category of health and physical hazard:
• An estimate (in ranges) of the
maximum amount of chemicals for
each category present at the facility
at any time during the preceding
calendar year;
• An estimate (in ranges) of the
average daily amount of chemicals
in each category; and
• The general location of hazardous
chemicals in each category.
Page A-5
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Tier I information shall be submitted on or
before March 1, 1988 and annually
thereafter on March 1.
The public may also request additional
information for specific facilities from the
SERC and LEPC. Upon the request of the
LEPC, the SERC, or the local fire
department, the facility must provide the
following Tier II information for each
covered substance to the organization
making the request:
• The chemical name or the common
name as indicated on the MSDS;
• An estimate (in ranges) of the
maximum amount of the chemical
present at any time during the
preceding calendar year;
• A brief description of the manner of
storage of the chemical;
• The location of the chemical at the
facility; and
• An indication of whether the owner
elects to withhold information from
disclosure to the public.
The information submitted by facilities
under Sections 311 and 312 musf
generally be made available to the public
by local and State governments during
normal working hours.
As in the case of the MSDS data, this
Section 312 information may be useful
for LEPCs interested in extending the
scope of their planning beyond the
facilities covered by Section 302, and
for reviewing and updating existing
plans. Section 312 information about
the quantity and location of chemicals
can be of use to fire departments in the
development of pre-fire plans. Section
312 data may be of limited use in the
initial planning process, given the fact
that initial emergency plans are to be
completed by October 17, 1988,
but they will be useful for the subse-
quent review and update of plans. Fa-
cility owners or operators, at the request
of the fire department, must allow the
fire department to conduct an on-site
inspection and\provide specific informa-
tion about the location of hazardous
chemicals.
Section 313:
Reporting
Toxic Chemical Release
Section 313 of; Title III requires EPA to
establish an inventory of toxic chemical
emissions from certain facilities. Facilities
subject to this reporting requirement must
complete a toxic chemical release form (to
be prepared by EPA by June 1987) for
specified chemicals. The form must be
submitted to EPA and those State officials
designated by the Governor on or before
July 1, 1988, and annually thereafter on
July 1, reflecting releases during each
preceding calendar year.
The purpose of this reporting requirement
is to inform government officials and the
public about releases of toxic chemicals
into the environment. It will also assist in
research . and i the development of
regulations, guidelines, and standards.
The reporting \ requirement applies to
owners and operators of facilities that
have 10 or more'full-time employees, that
are in Standard Industrial Classification
(SIC) Codes 20 through 39, and that
manufactured, processed, or otherwise
used a listed toxic chemical in excess of
specified threshold quantities. The SIC
Codes mentioned cover basically all
manufacturing industries.
Facilities using 'listed toxic chemicals in
quantities over' 10,000 pounds in a
calendar year are required to submit toxic
chemical release forms by July 1 of the
following year. Facilities manufacturing or
processing any of these chemicals in
excess of 75,000 pounds in 1987 must
report by July 1, 1988. Facilities
manufacturing or processing in excess of
50,000 pounds io 1988 must report by July
Page A-6
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1, 1989. Thereafter, facilities
manufacturing or processing more than
25,000 pounds in a year are required to
submit the form. EPA can revise these
threshold quantities and the SIC
categories involved.
The list of toxic chemicals subject to
reporting consists initially of chemicals
listed for similar reporting purposes by the
States of New Jersey and Maryland.
There are over 300 chemicals and
categories on these lists. EPA can modify
this combined list. In adding a chemical
to the combined Maryland and New Jersey
lists, EPA must consider the following
factors:
(1) Is the substance known to cause
cancer or serious reproductive or
neurological disorders, genetic
mutations, or other chronic health
effects?
(2) Can the substance cause
significant adverse acute health
effects as a result of continuous
or frequently recurring releases?
(3) Can the substance cause an
adverse effect on the environment
because of its toxicity,
persistence, or tendency to
bioaccumulate?
Chemicals can be deleted if there is not
sufficient evidence to establish any of
these factors. State Governors or any
other person may petition the EPA
Administrator to add or delete a chemical
from the list for any of the above reasons.
EPA must either publish its reasons for
denying the petition, or initiate action to
implement the petition within 180 days.
Through early consultation with States or
EPA Regions, petitioners can avoid
duplicating previous petitions and be
assisted in locating sources of data
already collected on the problem of
concern and data sources to support their
petitions. EPA will conduct information
searches on chemicals contained in a
petition, focusing on the effects the
petitioners believes warrant addition or
deletion.
The toxic chemical release form includes
the following information for released
chemicals:
• The name, location, and type of
business;
• Whether the chemical is
manufactured, processed, or
otherwise used and the general
categories of use of the chemical;
• An estimate (in ranges) of the
maximum amounts of the toxic
chemical present at the facility at
any time during the preceding year;
• Waste treatment and disposal
methods and the efficiency of
methods for each wastestream;
• The quantity of the chemical
entering each environmental
medium annually; and
• A certification by a senior official that
the report is complete and accurate.
EPA must establish and maintain a
national toxic chemical inventory based on
the data submitted. This information must
be computer accessible on a national
database.
In general these Section 313 reports
appear to be of limited value in emer-
gency planning. Over time, however
they may contain information that can
be used by local planners in developing
a more complete understanding of the
total spectrum of hazards that a given
facility may pose to a community.
These reports will not be available to
States until July 1, 1988. These reports
do not go to the LEPCs directly but they
are likely to become available if the
LEPCs request them from the States.
Page A-7
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Other Title III Provisions
In addition to these four major sections of
Title III, there are other provisions of
interest to local communities.
Preemption
Section 321 stipulates that (with the
exception of the MSDS format and
content required by Section 311) Title
HI does not preempt any State and local
laws. In effect, Title III imposes
minimum planning and reporting stan-
dards where no such standards (or less
stringent standards) exist, while
permitting States and localities to
pursue more stringent requirements as
they deem appropriate.
Trade Secrets
Section 322 of Title III addresses trade
secrets and applies to Section 303 emer-
gency planning and Sections 311, 312,
313 regarding planning information,
community right-to-know reporting
requirements, and toxic chemical release
reporting. Any person may withhold the
specific chemical identity of an extremely
hazardous substance or toxic chemical for
specific reasons. Even if the chemical
identity is withheld, the generic class or
category of the chemical must be
provided. Such information may be with-
held if the facility submits the withheld in-
formation to EPA along with an explanation
of why the information is a trade secret.
The Information may not be withheld as a
trade secret unless the facility shows
each of the following:
• The information has not been
disclosed to any other person other
than a member of the LEPC, a
government official, an employee of
such person or someone bound by a
confidentiality agreement, and that
measures . have been taken to
protect the confidentiality;
• The information is not required to be
disclosed to the public under any
other Federal or State law;
!
I
• The information is likely to cause
substantial harm to the competitive
position of the person; and
• The chemical identity could not
reasonably be discovered by anyone
in the absence of disclosure.
I
Even if information can be legally withheld
from the public, Section 323 requires it
not to be withheld from health
professionals who require the information
for diagnostic purposes or from local
health officials who require the information
for assessment activities. In these cases,
the person receiving the information must
be willing to sign a confidentiality
agreement with the facility.
Information claimed as trade secret and
substantiation for that claim must be
submitted to EPA. People may challenge
trade secret claims by petitioning EPA,
which must then review the claim and rule
on its validity. :
EPA will publish regulations governing
trade secret claims. The regulations will
cover the process for submission of
claims, petitions for disclosure, and a
review process for these petitions.
Enforcement j
Section 325 identifies the following en-
forcement procedures:
• Civil penalties for facility owners or
operators who fail to comply with
emergency planning requirements;
• Civil, administrative, and criminal
penalties for owners or operators
who fail to comply with the emer-
gency notification requirements of
Section 304;
Page A-8
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• Civil and administrative penalties for
owners or operators who fail to com-
ply with the reporting requirements
in Sections 311-313;
• Civil and administrative penalties for
frivolous trade secret claims; and
• Criminal penalties for the disclosure
of trade secret information.
In addition to the • Federal government,
State and local governments and individ-
ual citizens may enforce the provisions of
Title III through the citizen suit authority
provided in Section 326.
Training
Section 305 mandates that Federal
emergency training programs must
emphasize hazardous chemicals. It also
authorizes the Federal Emergency
Management Agency (FEMA) to provide
$5 million for each of fiscal years 1987,
1988, 1989, and 1990 for training grants
to support State and local governments.
These training grants are designed to
improve emergency planning,
preparedness, mitigation, response, and
recovery capabilities. Such programs
must give special emphasis to hazardous
chemical emergencies. The training
grants may not exceed 80 percent of the
cost of any such programs. The
remaining 20 percent must come from
non-Federal sources. Consult FEMA and/
or EPA Regional offices for a list of training
courses.
Review of Emergency Systems
Under Section 305, EPA has initiated a
review of emergency systems for
monitoring, detecting, and preventing
releases of extremely hazardous
substances at representative facilities that
produce, use, or store these substances.
It also is examining public alert systems.
EPA will report interim findings to the
Congress no later than May 17, 1987 and
issue a final report of findings and
recommendations to the Congress by
April 17, 1988.
The report must include EPA's findings
regarding each of the following:
• Status of current technological
capabilities to 1) monitor, detect,
and prevent significant releases of
extremely hazardous substances; 2)
determine the magnitude and
direction of the hazard posed by
each release; 3) identify specific
substances; 4) provide data on the
specific chemical composition of
such releases; and 5) determine
relative concentrations of the
constituent substances;
• Status of public emergency alert
devices or systems for effective
public warning of accidental releases
of extremely hazardous substances
into any media; and
• The technical and economic
feasibility of establishing,
maintaining, and operating alert
systems for detecting releases.
The report must also include EPA's
recommendations for the following:
• Initiatives to support development of
new or improved technologies or
systems that would assist the timely
monitoring, detection, and
prevention of releases of extremely
hazardous substances; and
• Improving devices or systems for
effectively alerting the public in the
event of an accidental release.
Page A-9
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EXHIBIT 5
KEY TITLE III DATES
The following is a list of some key dates relative to the implementation of the " Emergency
Planning and Community Right-to-Know Act of 1986." '.
November 17, 1986
November 17, 1986
January 27, 1987
March 17, 1987
April 17, 1987
'May 17, 1987
June 1, 1987
July 17, 1987
August 17, 1987
(or 30 days after
designation of
districts, which-
ever is sooner)
September 17, 1987
(or 30 days after
local committee is
formed, whichever
is earlier)
October 17, 1987
March 1, 1988
April 17, 1988
July 1, 1988
(and annually
hereafter)
October 17, 1988
EPA publishes interim final List of Extremely
Hazardous Substances and their Threshold Planning
Quantities in Federal Register (§ 302 (a) (2-3))
EPA initiates comprehensive review of emergency
systems (§ 305 (b)) l
EPA publishes proposed formats for emergency
inventory forms and reporting requirements in Federal
Register (§311-12)
i
National Response Team publishes guidance for
preparation and implementation of emergency plans
(§ 303 (f))
State Governors appoint SERCs (§ 301 (a))
Facilities subject to Section 302 planning requirements
notify SERC (§ 302 (c)) ,
EPA publishes toxic chemicals release (i.e., emissions
inventory) form (§ 302 (c));
i
SERC designates emergency planning districts
(§301(b»
SERC appoints members of LEPCs (§ 301 (c))
Facility notifies LEPC of selection of a facility
representative to serve as 'facility emergency
coordinator (§ 303(d)(1» |
MSDSs or list of MSDS chemicals submitted to SERC,
LEPC, and local fire department (§ 311(d))
Facilities submit their initial emergency inventory
forms to SERC, LEPC, and local fire department
(§ 312(a)(2» ;
Final report on emergency^ systems study due to
Congress (§ 305(b))
Facilities to submit initial toxic chemical release forms
to EPA and designated State officials (§ 313(a))
LEPCs complete preparation of an emergency plan
(§ 303(a))
Page A-10
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EXHIBIT 6
TITLE III - MAJOR INFORMATION FLOW/REQUIREMENTS
Guidance/
Assistance
(§303)
NRT
RRT
EPA
State
Commission
(SERC)
Designated
State Official
Emergency
Response Plan
Local
Committee
(LEPC)
Fire
Department
Emergency
Notification
(§304)
Emergency
Planning
(§301-§303)
Toxic Chemical
Release Form
(§313)
FACILITIES
Emergency
Inventory-
(§312)
MSDS
List
(§311)
-------
EXHIBIT 7
INFORMATION FROM FACILITIES PROVIDED BY TITLE
IN SUPPORT OF LEPC PLAN DEVELOPMENT
ill
Information Generated by
Title 111 Compliance
Authority
How LEPC Can Use
the Information
18
i—.
tvj
Facilities subject to Title III planning requirements
(including those designated by the Governor or SERC)
Additional facilities near subject facilities (such as hospitals,
natural gas facilities, etc.)
Transportation routes
Major chemical hazards (chemical name, properties,
location, and quantity)
Facility and community response methods, procedures,
and personnel
Facility and community emergency coordinators
Release detection and notification procedures
Methods for determining release occurrence and
population affected
Facility equipment and emergency facilities; persons
responsible for such equipment and facilities
Evacuation plans
Training programs
Exercise methods and schedules
Section 302;
Notice from Governor/SERC
Sections 302 (b) (2); 303 (c)(1)
Sections 303 (c)(1); 303 (d) (3)
Section 303 (d) (3) for extremely
hazardous substances used,
produced, stored
Section 311 MSDSs for chemicals
manufactured or imported
Section 312 inventories for
chemicals manufactured or imported
Sections 303 (c) (2); 303 (d) (3)
Sections 303(c) (3); 303(d)(1)
Sections 303(c) (4);. 303(d).(3)-
Sections 303 (c) (5); 303 (d) (3)
Sections 303 (c) (6); 303 (d) (3)
Sections 303 (c) (7); 303 (d) (3)
Sections 303 (c) (8); 303 (d) (3)
Sections 303 (c) (9); 303 (d) (3)
Hazards analysis — Hazards
identification (see p. 64)
Hazards analysis — Vulnerability
analysis (see p. 64)
Hazards analysis — Hazards
identification (see p. 64)
Hazards analysis — Hazards
identification (see p. 64)
Response functions (see pp. 49ff)
Assistance in preparing and
implementing the plan (see p. 11)
Initial- notification (see .p.. 50)
Warning systems (see p. 53)
Hazards analysis — Vulnerability
analysis and risk analysis (see p. 64)
Resource management (see p. 54)
Evacuation planning (see p. 57)
Resource management (see p. 54)
Testing and updating (see p. 63)
-------
EXHIBIT 8
TITLE III CHEMICAL LISTS AND THEIR PURPOSES
List
Required in Section
Purpose
Extremely Hazardous Substances
(Federal Register 11/17/86 — initially
402 chemicals listed in CEPP Interim
Guidance)
Section 302: Emergency Planning
Section 304: Emergency Notification
Facilities with more than established planning
quantities of these substances must notify the
SERC.
Initial focus for preparation of emergency plans
by LEPCs
Certain releases of these chemicals trigger
Section 304 notification to SERC and LEPC.
o
0=1
Substance requiring notification under
Section 103 (a) of CERCLA (717
chemicals)
Section 304: Emergency Notification
Certain releases of these chemicals trigger
Section 304 notification to SERC and LEPC as well
as CERCLA Section 103 (a) requirement to
notify National Response Center.
>— .
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-------
APPENDIX B
LIST OF ACRONYMS AND RECOGNIZED ABBREVIATIONS
AAR/BOE Association of American Railroads/Bureau of Explosives
AlChE American Institute of Chemical Engineers
ASCS Agricultural Stabilization and Conservation Service
ASME American Society of Mechanical Engineers
ASSE American Society of Safety Engineers
ATSDR Agency for Toxic Substances and Disease Registry (HHS)
CAER Community Awareness and Emergency Response (CMA)
CDC Centers for Disease Control (HHS)
CEPP Chemical Emergency Preparedness Program
CERCLA Comprehensive Environmental Response, Compensation, and Liabil-
ity Act of 1980 (PL 96-510)
CFR Code of Federal Regulations
CHEMNET A mutual aid network of chemical shippers and contractors.
CHEMTREC Chemical Transportation Emergency Center
CHLOREP A mutual aid group comprised of shippers and carriers of chlorine.
CHRIS/HACS Chemical Hazards Response Information System/Hazard Assessment
Computer System
CMA Chemical Manufacturers Association
CPG 1-3 Federal Assistance Handbook: Emergency Management, Direction
and Control Programs
CPG 1-8 Guide for Development of State and Local Emergency Operations
Plans
CPG 1-8A Guide for the Review of State and Local Emergency Operations
Plans
CWA Clean Water Act
DOC U.S. Department of Commerce
DOD U.S. Department of Defense
DOE U.S. Department of Energy
DOI U.S. Department of the Interior
DOJ U.S. Department of Justice
DOL U.S. Department of Labor
DOS U.S. Department of State
DOT U.S. Department of Transportation
Page B-l
-------
APPENDIX B (Continued)
LIST OF ACRONYMS AND RECOGNIZED ABBREVIATIONS
EENET
EMA
EMI
EOC
EOF
EPA
ERD
FEMA
FEMA-REP-5
FWPCA
HAZMAT
HAZOP
HHS
ICS
IEMS
LEPC
MSDS
NACA
NCP
NCRIC
NETC
NFA
NFPA
NIOSH
NOAA
NRC
NRT
NUREG 0654/
FEMA-REP-1
OHMTADS
Emergency Education Network (FEMA) :
Emergency Management Agency
Emergency Management Institute
Emergency Operating Center
Emergency Operations Plan ;
U.S. Environmental Protection Agency :
Emergency Response Division (EPA) I
Federal Emergency Management Agency
Guidance for Developing State and Local Radiological Emergency
Response Plans and Preparedness for Transportation Accidents
Federal Water Pollution Control Act
Hazardous Materials
Hazard and Operability Study
U.S. Department of Health and Human Services
Incident Command System ;
i
Integrated Emergency Management System,
Local Emergency Planning Committee |
Material Safety Data Sheet !
National Agricultural Chemicals Association •
National Contingency Plan j
National Chemical Response and Information Center (CMA)
National Emergency Training Center :
National Fire Academy
National Fire Protection Association
National Institute of Occupational Safety and Health
National Oceanic and Atmospheric Administration
U.S. Nuclear Regulatory Commission; National Response Center
National Response Team
Criteria for Preparation and Evaluation of Radiological Emergency
Response Plans and Preparedness in Support of Nuclear Power
Plants
Oil and Hazardous Materials Technical Assistance Data System
Page B-2
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APPENDIX B (Continued)
LIST OF ACRONYMS AND RECOGNIZED ABBREVIATIONS
osc
OSHA
PSTN
RCRA
RQs
RRT
RSPA
SARA
SCBA
SERC
SPCC
TSD
USCG
USDA
USGS
USNRC
On-Scene Coordinator
Occupational Safety and Health Administration (DOL)
Pesticide Safety Team Network
Resource Conservation and Recovery Act
Reportable Quantities
Regional Response Team
Research and Special Programs Administration (DOT)
Superfund Amendments and Reauthorization Act of 1986
(PL 99-499)
Self-Contained Breathing Apparatus
State Emergency Response Commission
Spill Prevention Control and Countermeasures
Treatment, Storage, and Disposal Facilities
U.S. Coast Guard (DOT)
U.S. Department of Agriculture
U.S. Geological Survey
U.S. Nuclear Regulatory Commission
Page B-3
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APPENDIX C
GLOSSARY
CAER
CEPP
CERCLA
CHEMNET
CHEMTREC
CHLOREP
- Community Awareness and Emergency Response program devel-
oped by the Chemical Manufacturers Association. Guidance for
chemical plant managers to assist them in taking the initiative in
cooperating with local communities to develop integrated (com-
munity/industry) hazardous materials response plans.
- Chemical Emergency Preparedness Program developed by EPA
to address accidental releases of acutely toxic chemicals.
- Comprehensive Environmental Response, Compensation, and Li-
ability Act regarding hazardous substance releases into the envi-
ronment and the cleanup of inactive hazardous waste disposal
sites.
- A mutual aid network of chemical shippers and contractors.
CHEMNET has more than fifty participating companies with emer-
gency teams, twenty-three subscribers (who receive services in
an incident from a participant and then reimburse response and
cleanup costs), and several emergency response contractors.
CHEMNET is activated when a member shipper cannot respond
promptly to an incident involving that company's product(s) and
requiring the presence of a chemical expert. If a member com-
pany cannot go the scene of the incident, the shipper will author-
ize a CHEMNET-contracted emergency response company to go.
Communications for the network are provided by CHEMTREC,
with the shipper receiving notification and details about the inci-
dent from the CHEMTREC communicator.
• Chemical Transportation Emergency Center operated by the
Chemical Manufacturers Association. Provides information and/or
assistance to emergency responders. CHEMTREC contacts the
shipper or producer of the material for more detailed information,
including on-scene assistance when feasible. Can be reached
24 hours a day by calling 800-424-9300. (Also see "HIT.")
Chlorine Emergency Plan operated by the Chlorine Institute. A
24-hour mutual aid program. Response is activated by a
CHEMTREC call to the designated CHLOREP contact, who notifies
the appropriate team leader, based upon CHLOREP's geographi-
cal sector assignments for teams. The team leader in turn calls
the emergency caller at the incident scene and determines what
advice and assistance are needed. The team leader then de-
cides whether or not to dispatch his team to the scene.
Page C-1
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APPENDIX C (Continued)
GLOSSARY
CHRIS/HAGS — Chemical Hazards Response Information System/Hazard Assess-
ment Computer System developed by the U.S. Coast Guard.
HAGS is a computerized model of the four CHRIS manuals that
contain chemical-specific data. Federal bSCs use HAGS to find
answers to specific questions during a chemical spill/response.
State and local officials and industry representatives may ask an
OSC to request a HAGS run for contingency planning purposes.
CpG 1-3 — Federal Assistance Handbook: Emergency Management, Direc-
tion and Control Programs, prepared by FEMA. Provides States
with guidance on administrative and programmatic requirements
associated with FEMA funds.
CPG 1-5 — Objectives for Local Emergency Management, prepared by
FEMA. Describes and explains functional objectives that repre-
sent a comprehensive and integrated emergency management
program. Includes recommended activities for each objective.
CPG 1-8 — Guide for Development of State and Local Emergency Operations
Plans, prepared by FEMA (see EOP below).
CPG 1-8A — Guide for the Review of State and Local Emergency Operations
Plans, prepared by FEMA. Provides FEMA staff with a standard
instrument for assessing EOPs that are developed to satisfy the
eligibility requirement to receive Emergency Management Assis-
tance funding. ;
CPG 1-35 — Hazard Identification, Capability Assessment, and Multi-Year De-
velopment Plan for Local Governments, prepared by FEMA. As a
planning tool, it can guide local jurisdictidns through a logical se-
quence for identifying hazards, assessing capabilities, setting pri-
orities, and scheduling activities to improve capability over time.
EBS — Emergency Broadcasting System to be used to inform the public
about the nature of a hazardous materials incident and what
safety steps they should take.
— The Emergency Management Institute is ;a component of FEMA's
National Emergency Training Center located in Emmitsburg, Mary-
land. It conducts resident and nonresident training activities for
Federal, State, and local government officials, managers in the
private economic sector, and members of professional and vol-
unteer organizations on subjects that range from civil nuclear
preparedness systems to domestic emergencies caused by natu-
ral and technological hazards. Nonresident training activities are
also conducted by State Emergency Management Training Offices
under cooperative agreements that offer, financial and technical
assistance to establish annual training programs that fulfill emer-
gency management training requirements in communities
throughout the nation.
Page C-2
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APPENDIX C (Continued)
GLOSSARY
ERT
EOP
FAULT-TREE
ANALYSIS
FEMA-REP-5
HAZARDOUS
MATERIALS
- Environmental Response Team, a group of highly specialized ex-
perts available through EPA 24 hours a day.
• Emergency Operations Plan developed in accord with the guid-
ance in CPG 1-8. EOPs are multi-hazard, functional plans that
treat emergency management activities generically. EOPs pro-
vide for as much generally applicable capability as possible with-
out reference to any particular hazard; then they address the
unique aspects of individual disasters in hazard-specific appendi-
ces.
A means of analyzing hazards. Hazardous events are first iden-
tified by other techniques such as HAZOP. Then all combinations
of individual failures that can lead to that hazardous event are
shown in the logical format of the fault tree. By estimating the
individual failure probabilities, and then using the appropriate ar-
ithmetical expressions, the top-event frequency can be calcu-
lated.
Guidance for Developing State and Local Radiological Emergency
Response Plans and Preparedness for Transportation Accidents,
prepared by FEMA. Provides a basis for State and local govern-
ments to develop emergency plans and improve emergency pre-
paredness for transportation accidents involving radioactive mate-
rials.
Refers generally to hazardous substances, petroleum, natural
gas, synthetic gas, acutely toxic chemicals, and other toxic
chemicals.
HAZOP
Hazard and operability study, a systematic technique for identify-
ing hazards or operability problems throughout an entire facility.
One examines each segment of a process and lists all possible
deviations for normal operating conditions and how they might
occur. The consequences on the process are assessed, and
the means available to detect and correct the deviations are ex-
amined.
HIT
Hazard Information Transmission program provides a digital
transmission of the CHEMTREC emergency chemical report to
first responders at the scene of a hazardous materials incident.
The report advises the responder on the hazards of the materi-
als, the level of protective clothing required, mitigating action to
take in the event of a spill, leak or fire, and first aid for victims.
HIT is a free public service provided by the Chemical Manufactur-
ers Association. Reports are sent in emergency situations only
to organizations that have pre-registered with HIT. Brochures
and registration forms may be obtained by writing: Manager,
CHEMTREC/CHEMNET, 2501 M Street, N.W., Washington, DC,
20037.
Page C-3
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APPENDIX C (Continued)
GLOSSARY
ICS — Incident Command System, the combination of facilities,
equipment, personnel, procedures, and pommunications operat-
ing within a common organizational structure with responsibility
for management of assigned resources to effectively accomplish
stated objectives at the scene of an incident.
IEMS — Integrated Emergency Management System, developed by FEMA
in recognition of the economies realized in planning for all haz-
ards on a generic functional basis as opposed to developing in-
dependent structures and resources to deal with each type, of
hazard.
NCP — National Oil and Hazardous Substances Pollution Contingency Plan
(40 CFR Part 300), prepared by EPA to put into effect the re-
sponse powers and responsibilities created by CERCLA and the
authorities established by Section 311 of; the Clean Water Act.
i
NFA — The National Fire Academy is a component of FEMA's National
Emergency Training Center located in Erpmitsburg, Maryland. It
provides fire prevention and control training for the fire service
and allied services. Courses on campus are offered in technical,
management, and prevention subject areas. A growing off-cam-
pus course delivery system is operated in conjunction with State
fire training program offices. !
NHMIE — National Hazardous Materials Information Exchange, provides
information on hazmat training courses, planning techniques,
events and conferences, and emergency response experiences
and lessons learned. Call toll-free 1-800-752-6367 (in Illinois,
1-800-367-9592). Planners with personal computer capabilities
can access NHMIE by dialing FTS 972-3275 or (312) 972-3275.
— National Response Center, a communications center for activities
related to response actions, is located at Coast Guard headquar-
ters in Washington, DC. The NRG receives and relays notices of
discharges or releases to the appropriate CSC, disseminates
OSC and RRT reports to the NRT when appropriate, and provides
facilities for the NRT to use in coordinating a national response
action when required. The toll-free number (800-424-8802, or
202-426-2675 or 202-267-2675 in the Washington, DC area) can
be reached 24 hours a day for reporting actual or potential pollu-
tion incidents. :
— National Response Team, consisting of Representatives of 14
government agencies (DOD, DOI, DOT/RSPA, DOT/USCG, EPA,
DOC, FEMA, DOS, USDA, DOJ, HHS, DOL, Nuclear Regulatory
Commission, and DOE), is the principal!organization for imple-
menting the NCP. When the NRT is notj activated for a response
action, it serves as a standing committee to develop and main-
tain preparedness, to evaluate methods of responding to dis-
charges or releases, to recommend needed changes in the re-
Page C-4
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APPENDIX C (Continued)
GLOSSARY
NSF
NUREG 06547
FEMA-REP-1
sponse organization, and to recommend revisions to the NCR.
The NRT may consider and make recommendations to appropri-
ate agencies on the training, equipping, and protection of re-
sponse teams; and necessary research, development, demon-
stration, and evaluation to improve response capabilities.
- National Strike Force, made up of three Strike Teams.
The USCG counterpart to the EPA ERTs.
Criteria for Preparation and Evaluation of Radiological Emergency
Response Plans and Preparedness in Support of Nuclear Power
Plants, prepared by NRC and FEMA. Provides a basis for State
and local government and nuclear facility operators to develop
radiological emergency plans and improve emergency prepared-
ness. The criteria also will be used by Federal agency reviewers
in determining the adequacy of State, local, and nuclear facility
emergency plans and preparedness.
OHMTADS
OSC
PSTN
- Oil and Hazardous Materials Technical Assistance Data System, a
computerized data base containing chemical, biological, and toxi-
cological information about hazardous substances. OSCs use
OHMTADS to identify unknown chemicals and to learn how to
best handle known chemicals.
- On-Scene Coordinator, the Federal official predesignated by EPA
or USCG to coordinate and direct Federal responses and remov-
als under the NCP; or the DOD official designated to coordinate
and direct the removal actions from releases of hazardous sub-
stances, pollutants, or contaminants from DOD vessels and facili-
ties. When the NRC receives notification of a pollution incident,
the NRC Duty Officer notifies the appropriate OSC, depending on
the location of an incident. Based on this initial report and any
other information that can be obtained, the OSC makes a prelimi-
nary assessment of the need for a Federal response. If an on-
scene response is required, the OSC will go to the scene and
monitor the response of the responsible party or State or local
government. If the responsible party is unknown or not taking
appropriate action, and the response is beyond the capability of
State and local governments, the OSC may initiate Federal ac-
tions, using funding from the FWPCA Pollution Fund for oil dis-
charges and the CERCLA Trust Fund (Superfund) for hazardous
substance releases.
• Pesticide Safety Team Network operated by the National Agricul-
tural Chemicals Association to minimize environmental damage
and injury arising from accidental pesticide spills or leaks. PSTN
area coordinators in ten regions nationwide are available 24
hours a day to receive pesticide incident notifications from
CHEMTREC.
Page C-5
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APPENDIX C (Continued)
GLOSSARY
RCRA
RRT
SARA
Superfund
Title III
Resource Conservation and Recovery Act (of 1976) established a
framework for the proper management arid disposal of all
wastes. RCRA directed EPA to identify hazardous wastes, both
generically and by listing specific wastes and industrial process
waste streams. Generators and transporters are required to use
good management practices and to track the movement of
wastes with a manifest system. Owners and operators of treat-
ment, storage, and disposal facilities also must comply with stan-
dards, which are generally implemented through permits issued
by EPA or authorized States.
- Regional Response Teams composed of representatives of Fed-
eral agencies and a representative from each State in the Fed-
eral region. During a response to a major hazardous materials
incident involving transportation or a fixed facility, the OSC may
request that the RRT be convened to provide advice or recom-
mendations in specific issues requiring resolution. Under the
NCP, RRTs may be convened by the chairman when a hazardous
materials discharge or release exceeds the response capability
available to the OSC in the place where it occurs; crosses re-
gional boundaries; or may pose a substantial threat to the public
health, welfare, or environment, or to regionally significant
amounts of property. Regional contingency plans specify de-
tailed criteria for activation of RRTs. RRTs may review plans de-
veloped in compliance with Title III, if the local emergency plan-
ning committee so requests. ;
- The "Superfund Amendments and Reauthorization Act of 1986."
Title III of SARA includes detailed provisions for community plan-
ning. |
- The trust fund established under CERCLA to provide money the
OSC can use during a cleanup. \
i
- The " Emergency Planning and Community Right-to-Know Act of
1986." Specifies requirements for organizing the planning proc-
ess at the State and local levels for specified extremely hazard-
ous substances; minimum plan content; :requirements for fixed
facility owners and operators to inform officials about extremely
hazardous substances present at the facilities; and mechanisms
for making information about extremely hazardous substances
available to citizens. (See Appendix A.)
Page C-6
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APPENDIX D
CRITERIA FOR ASSESSING STATE AND
LOCAL PREPAREDNESS
C.1 INTRODUCTION
The criteria in this appendix, an adaptation of criteria developed by the Preoaredness
Committee of the NRT in August 1985, represent a basis for assessing a Sate oMocal
hazardous materials emergency response preparedness program. These criteria reflect
nrnn±IC " ***** '° ta lmport
-------
D Was it done in accordance with community right-to-know laws and prefire
plans?
D Does it include the routes by which the hazardous materials are transported?
D Have areas of public health concern been identified? |
D Have sensitive environmental areas been identified?
i
D Have historical data on spill incidents been collected jand evaluated?
D Have the levels of vulnerability and probable locations of hazardous materials
incidents been identified?
D Are environmentally sensitive areas and population centers considered in ana-
lyzing the hazards of the transportation routes and fixed facilities?
C.2.2 Authority
"Authority" refers to those statutory authorities or other legal! authorities vested in any
personnel, organizations, agencies, or other entities in responding to or being prepared
for responding to hazardous materials emergencies resulting from releases or spills.
The following criteria may be used to assess the existing legal authorities for response
actions: :
D Do clear legal authorities exist to establish a comprehensive hazardous materials
response mechanism (Federal, State, county, and local laws, ordinances, and
policies)? ;
D Do these authorities delegate command and control responsibilities between the
different organizations within the same level of government (horizontal), and/or
provide coordination procedures to be followed? j
D Do they specify what agency(ies) has (have) overall Responsibility for directing
or coordinating a hazardous materials response? |
D Do they specify what agency(ies) has (have) responsibility for providing assis-
tance or support for hazardous materials response jand what comprises that
assistance or support? ;
D Have the agency(ies) with authority to order evacuatibn of the community been
identified? ,
D Have any limitations in the legal authorities been identified?
C.2.3 Organizational Structure
"Organization" refers to the organizational structure in place for responding to emergen-
cies. This structure will, of course, vary considerably from State to State and from locality
to locality. ;
There are two basic types of organizations involved in emergency response operations.
The first is involved in the planning and policy decision process similar to the NRT and
RRT The second is the operational response group that functions within the precepts set
forth in the State or local plan. Realizing that situations vary from State to State and
Page D-2
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ocalrty to locality and that emergency planning for the State and local level may involve
he preparation of multiple situation plans or development of a single comprehensle plan,
he criteria should be broadly based and designed to detect a potential flaw that would
then precipitate a more detailed review.
D Are the following organizations included in the overall hazardous materials emer-
gency preparedness activities?
• Health organizations (including mental health organizations)
• Public safety
o fire
o police
o health and safety (including occupational safety and health)
o other responders
• Transportation
• Emergency management/response planning
• Environmental organizations
• Natural resources agencies (including trustee agencies)
• Environmental agencies with responsibilities for:
o fire
o health
o water quality
o air quality
o consumer safety
• Education system (in general)
o public education
o public information
• Private sector interface
o trade organizations
o industry officials
• Labor organizations
D Have each organization's authorities, responsibilities, and capabilities been de-
termined for pre-response (planning and prevention), response (implementing
the plan during an incident), and post-response (cleanup and restoration) activi-
ties?
Page D-3
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D Has one organization been given the command and control responsibility for
these three phases of emergency response? i
D Has a "chain of command" been established for response control through all
levels of operation?
D Are the roles, relationships, and coordination procedures between government
and non-government (private entities) delineated? Are they understood by all
affected parties? How are they instituted (written, verbal)?
D Are clear interrelationships, and coordination procedures between government
and non-government (private entities) delineated? Are they understood by all
affected parties? How are they instituted (written, verbal)?
D Are the agencies or departments that provide technical guidance during a re-
sponse the same agencies or departments that provide technical guidance in
non-emergency situations? In other words, does the organizational structure
vary with the type of situation to be addressed?
D Does the organizational structure provide a mechanism to meet regularly for
planning and coordination?
D Does the organizational structure provide a mechanism to regularly exercise the
response organization?
i
D Has a simulation exercise been conducted within the iast year to test the organ-
izational structure?
D Does the organizational structure provide a mechanism to review the activities
conducted during a response or exercise to correct :shortfalls?
D Have any limitations within the organizational structure been identified?
D Is the organizational structure compatible with the Federal response organization
in the NCP?
D Have trained and equipped incident commanders been identified?
D Has the authority for site decisions been vested in the incident commanders?
D Have the funding sources for a response been identified?
D How quickly can the response system be activated?
i
C.2.4 Communication ',
"Communication" means any form or forms of exchanging information or ideas for emer-
gency response with other entities, either internal or external to the existing organizational
structure.
Coorc//naf/on:
D Have procedures been established for coordination pf information during a re-
sponse?
D Has one organization been designated to coordinate communications activities?
Page D-4
-------
D Have radio frequencies been established to facilitate coordination between dif-
ferent organizations?
Information Exchange:
n Does a formal system exist for information sharing among agencies, organiza-
tions, and the private sector?
D Has a system been established to ensure that "lessons learned" are passed to
the applicable organizations?
Informa tion Dissemina tion:
D Has a system been identified to carry out public information/community relations
activities?
D Has one organization or individual been designated to coordinate with or speak
to the media concerning the release?
D Is there a communication link with an Emergency Broadcast System (EBS) point
of entry (CPCS-1) station?
D Does a communications system/method exist to disseminate information to re-
sponders, affected public, etc.?
D Is this system available 24-hours per day?
D Have alternate systems/methods of communications been identified for use if
the primary method fails?
D Does a mechanism exist to keep telephone rosters up-to-date?
D Are communications networks tested on a regular basis?
Information Sources and Database Sharing:
n Is a system available to provide responders with rapid information on the haz-
ards of chemicals involved in an incident?
D Is this information available on a 24-hour basis? Is it available in computer soft-
ware?
D Is a system in place to update the available information sources?
Notification Procedures:
D Have specific procedures for notification of a hazardous materials incident been
developed?
D Are multiple notifications required by overlapping requirements (e.g., State,
county, local each have specific notification requirements)?
D Does the initial notification system have a standardized list of information that is
collected for each incident?
D Does a network exist for notifying and activating necessary response personnel?
Page D-5
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D Does a network exist for notifying or warning the public of potential hazards re-
sulting from a release? Does this network have provisions for informing the
public what hazards to expect, what precautions to t4ke, whether evacuation is
required, etc.? '.
D Has a central location or phone number been established for initial notification of
an incident?
D Is the central location or phone number accessible on a 24-hour basis?
D Does the central location phone system have the ability to expand to a multiple
line system during an emergency?
Clearinghouse Functions:
D Has a central clearinghouse for hazardous materials information been estab-
lished with access by the public and private sector? ,
C.2.5 Resources j . .
"Resource" means the personnel, training, equipment, facilities, and other sources avail-
able for use in responding to hazardous materials emergencies. To the extent that the
hazards analysis has identified the appropriate level of preparedness for the area, these
criteria may be used in evaluating available resources of the jurisdiction undergoing re-
view.
Personnel: i
H Have the numbers of trained personnel available for 'hazardous materials been
determined?
D Has the location of trained personnel available for hazardous materials been
determined? Are these personnel located in areas identified in the hazards
analysis as:
i .'
• heavily populated;
• high hazard areas - i.e., numbers of chemical (or other hazardous materi-
als) production facilities in well-defined areas;
• hazardous materials storage, disposal, and/or treatment facilities; and
• transit routes?
O Are sufficient personnel available to maintain a given level of response capability
identified as being required for the area?
D Has the availability of special technical expertise (chemists, industrial hygienists,
toxicologists, occupational health physicians, etc.) necessary for response been
identified?
D Have limitations on the use of above personnel resources been identified?
Q Do mutual aid agreements exist to facilitate interagency support between organi-
zations?
Page D-6
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Training:
D Have the training needs for the State/local area been identified?
D Are centralized response training facilities available?
D Are specialized courses available covering topics such as:
• organizational structures for response actions (i.e., authorities and coordi-
nation) ;
• response actions;
• equipment selection, use, and maintenance; and
• safety and first aid?
D Does the organizational structure provide training and cross training for or be-
tween organizations in the response mechanism?
D Does an organized training program for all involved response personnel exist?
Has one agency been designated to coordinate this training?
D Have training standards or criteria been established for a given level of response
capability? Is any certification provided upon completion of the training?
D Has the level of training available been matched to the responsibilities or capa-
bilities of the personnel being trained?
D Does a system exist for evaluating the effectiveness of training?
D Does the training program provide for "refresher courses" or some other
method to ensure that personnel remain up-to-date in ,their level of expertise?
D Have resources and organizations available to provide training been identified?
D Have standardized curricula been established to facilitate consistent Statewide
training?
Equipment:
D Have response equipment requirements been identified for a given level of re-
sponse capability?
D Are the following types of equipment available?
• personal protective equipment
• first aid and other medical emergency equipment
• emergency vehicles available for hazardous materials response
• sampling equipment (air, water, soil, etc.) and other monitoring devices
(e.g., expldsivity meters, oxygen meters)
• analytical equipment or facilities available for sample analyses
Page D-7
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• fire-fighting equipment/other equipment and material (bulldozers, boats,
helicopters, vacuum trucks, tank trucks, chemical retardants, foam)
i
D Are sufficient quantities of each type of equipment available on a sustained ba-
sis?
D Is all available equipment capable of operating in the local environmental condi-
tions? :
D Are up-to-date equipment lists maintained? Are they computerized?
Q Are equipment lists available to all responders? !
D Are these lists broken down into the various types of equipment (e.g., protec-
tive clothing, monitoring instruments, medical supplies, transportation equip-
ment)? !
i
D Is there a mechanism to ensure that the lists are kept up-to-date?
i
D Have procedures necessary to obtain equipment on a 24-hour basis been identi-
fied? ;
D Does a program exist to carry out required maintenance of equipment?
D Are there maintenance and repair records for each piece of equipment?
i
D Have mutual aid agreements been established for the use of specialized re-
sponse equipment?
D Is sufficient communications equipment available for notifying personnel or to
transmit information? Is the equipment of various participating agencies com-
patible? ;
D Is transportation equipment available for moving equipment rapidly to the scene
of an incident, and its state of readiness assured? :
Facilities: i
i
D Have facilities capable of performing rapid chemical analyses been identified?
I
i
D Do adequate facilities exist for storage and cleaning/reconditioning of response
equipment? :
D Have locations or facilities been identified for the storage, treatment, recycling,
and disposal of wastes resulting from a release?
!
D Do adequate facilities exist for carrying out training programs?
D Do facilities exist that are capable of providing medical treatment to persons
injured by chemical exposure? ]
i
n Have facilities and procedures been identified for housing persons requiring
evacuation or temporary relocation as a result of an ^incident?
L
D Have facilities been identified that are suitable for command centers?
Page D-8
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C.2.6 Emergency Plan
The emergency plan, while it relates to many of the above criteria, also stands alone as a
means to assess preparedness at the State and local level of government, and in the
private sector. The following questions are directed more toward evaluating the plan
rather than determining the preparedness level of the entity that has developed the plan.
It is not sufficient to ask if there is a plan, but rather to determine if the plan that does exist
adequately addresses the needs of the community or entity for which the plan was devel-
oped.
D Have the levels of vulnerability and probable locations of hazardous materials
incidents been identified in the plan?
D Have areas of public health concern been identified in the plan?
D Have sensitive environmental areas been identified in the plan?
D For the hazardous materials identified in the area, does the plan include informa-
tion on the chemical and physical properties of the materials, safety and emer-
gency response information, and hazard mitigation techniques? (NOTE: It is not
necessary that all this information be included in the emergency plan; the plan
should, however, at least explain where such information is available.)
n Have all appropriate agencies, departments, or organizations been involved in
the process of developing or reviewing the plan?
D Have all the appropriate agencies, departments, or organizations approved the
plan?
D Has the organizational structure and notification list defined in the plan been
reviewed in the last six months?
D Is the organizational structure identified in the plan compatible with the Federal
response organization in the NCR?
D Has one organization been identified in the plan as having command and control
responsibility for the pre-response, response, and post response phases?
n Does the plan define the organizational responsibilities and relationships among
city, county, district, State, and Federal response agencies?
D Are all organizations that have a role in hazardous materials response identified
in the plan (public safety and health, occupational safety and health, transporta-
tion, natural resources, environmental, enforcement, educational, planning, and
private sector)?
D Are the procedures and contacts necessary to activate or deactivate the organi-
zation clearly given in the plan for the pre-response, response, and post-re-
sponse phases?
D Does the organizational structure outlined in the plan provide a mechanism to
review the activities conducted during a response or exercise to correct short-
falls?
D Does the plan include a communications system/method to disseminate infor-
mation to responders, affected public, etc.?
Page D-9
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D Has a system been identified in the plan to carry out public information/commu-
nity relations activities? j
D Has a central location or phone number been included in the plan for initial notifi-
cation of an incident? ;
D Have trained and equipped incident commanders been identified in the plan?
D Does the plan include the authority for vesting site decisions in the incident com-
mander? •
D Have government agency personnel that may be involved in response activities
been involved in the planning process? j
D Have local private response organizations (e.g., chemical manufacturers, com-
mercial cleanup contractors) that are available to assist during a response been
identified in the plan? '
D Does the plan provide for frequent training exercises to train personnel or to test
the local contingency plans? '
D Are lists/systems that identify emergency equipment available to response per-
sonnel included in the plan? ',
D Have locations of materials most likely to be used in mitigating the effects of a
release (e.g., foam, sand, lime) been identified in the plan?
D Does the plan address the potential needs for evacuation, what agency is
authorized to order or recommend an evacuation, how it will be carried out, and
where people will be moved?
D Has an emergency operating center, command center, or other central location
with the necessary communications capabilities been! identified in the plan for
coordination of emergency response activities? :
!
D Are there follow-up response activities scheduled in the plan?
D Are there procedures for updating the plan?
D Are there addenda provided with the plan, such as: laws and ordinances, statu-
tory responsibilities, evacuation plans, community relations plan, health plan,
and resource inventories (personnel, equipment, maps [not restricted to road
maps], and mutual aid agreements)?
D Does the plan address the probable simultaneous occurrence of different types
of emergencies (e.g., power outage and hazardous materials releases) and the
presence of multiple hazards (e.g., flammable and corrosive) during hazardous
materials emergencies?
Page D-10
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APPENDIX E
BIBLIOGRAPHY
General Emergency Planning for Hazardous Materials
American Institute of Chemical Engineers, Center for Chemical Plant Safety. Guide-
lines for Hazard Evaluation Procedures. Washington, DC: A.I.Ch.E., 1985.
American Society of Testing & Materials. Toxic and Hazardous Industrial Chemicals
Safety Manual. 1983.
Association of Bay Area Governments. San Francisco Bay Area: Hazardous Spill Pre-
vention and Response Plan. Volumes I & II. Berkeley, CA: 1983.
Avoiding and Managing Environmental Damage from Major Industrial Accidents. Proc.
of Conference of the Air Pollution Control Association. 1985.
Bretherick, L. Handbook of Reactive Chemical Hazards. 2nd ed. Butterworth, 1979.
Brinsko, George A. et al. Hazardous Material Spills and Responses for Municipalities.
(EPA-600/2-80-108, NTIS PB80-214141). 1980.
Cashman, John R. Hazardous Materials Emergencies: Response and Control. 1983.
Chemical Manufacturers Association. Community Awareness and Emergency Response
Program Handbook. Washington, DC: CMA, 1985.
Chemical Manufacturers Association. Community Emergency Response Exercise Pro-
gram. Washington, DC: CMA, 1986.
Chemical Manufacturers Association. Risk Analysis in the Chemical Industry - Proceed-
ings of a Symposium. Rockville, MD: Government Institutes, Inc., 1985.
Chemical Manufacturers Association. Site Emergency Response Planning. Washington,
DC: CMA, 1986.
Copies of the CMA guides can be obtained by writing to:
Publications Fulfillment
Chemical Manufacturers Association
2501 M Street, N.W.
Washington, D.C. 20037
Emergency Management and Civil Defense Division, Consolidated City of Indianapolis.
Final Report: Demonstration Project to Develop a Hazardous Materials Accident Preven-
tion and Emergency Response Program, Phases I, II, III, IV. Indianapolis: 1983.
Energy Resources Co., Inc.; Cambridge Systematics, Inc.; Massachusetts Department
of Environmental Quality Engineering. Demonstration Project to Develop a Hazardous
Materials Accident Prevention and Emergency Response Program for the Commonwealth
of Massachusetts. Volumes I & II. Cambridge and Boston, MA: 1983.
Environmental and Safety Design, Inc. Development of a Hazardous Materials Accident
Prevention and an Emergency Response Program. Memphis, TN: 1983.
Page E-l
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Federal Emergency Management Agency. Disaster Operations: A Handbook for Local
Governments. Washington, DC: 1981. ;
Federal Emergency Management Agency. Hazard Identificatiop, Capability Assess-
ment, and Multi-Year Development Plan for Local Governments. CPG 1-35, Washing-
ton, DC: 1985.
Federal Emergency Management Agency. Objectives for Local Emergency Manage-
ment. CPG 1-5, Washington, DC: 1984. !
i
Federal Emergency Management Agency. Professional Development Series: Emer-
gency Planning — Student Manual. Washington, DC. ;
[
Federal Emergency Management Agency. Professional Development Series: Introduc-
tion to Emergency Management — Student Manual. Washington, DC.
Gabor, T. and T.K. Griffith. The Assessment of Community Vulnerability to Acute Haz-
ardous Materials Incidents. Newark, DE: University of Delaware, 1985.
Government Institutes, Inc. Md. R.C.R.A. Hazardous Waste Handbook. Volumes 1 & 2.
1981. '
Green, Don W., ed. Perry's Chemical Engineers' Handbook. 6th ed. McGraw-Hill,
1984. j
Hawley, Gessner G., ed. Condensed Chemical Dictionary. 10j:h ed. New York: Van
Nostrand Reinhold, 1981. ;
Hildebrand, Michael S. Disaster Planning Guidelines for Fire Chiefs. Washington, DC:
International Association of Fire Chiefs, 1980.
Multnomah County Office of Emergency Management. Hazardous Materials Manage-
ment System: A Guide for Local Emergency Managers. Portland, OR: 1983.
National Fire Protection Association. Fire Protection Guide on Hazardous Materials.
Boston: NFPA, 1986. ',
i
National Institute of Occupational Safety and Health. Pocket Guide to Chemical Haz-
ards. Washington, DC: DHEW (NIOSH) 78-210, 1985. (GPO Stock No.
017-033-00342-4) i
New Orleans, City of. Demonstration Project to Develop a Hazardous Materials Acci-
dent Prevention and Emergency Response Program for the City of New Orleans, Phases
I, II, III, IV. New Orleans: 1983. .
Portland Office of Emergency Management. Hazardous Materials Hazard Analysis.
Portland, OR: 1981. \
Puget Sound Council of Governments. Hazardous Materials Demonstration Project Re-
port: Puget Sound Region. Seattle, WA: 1981. :
Sax, N. Irving. Dangerous Properties of Industrial Materials. 6th ed. New York: Van
Nostrand Reinhold, 1984. i
Sittig, Marshall. Handbook of Toxic and Hazardous Chemicals and Carcinogens.
Noyes, 1985. i
i
Smith, Al J. Managing Hazardous Substances Accidents. 198;1.
Page E-2 ;
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U.S. Department of Transportation. CHRIS: Manual I, A Condensed Guide to Chemical
Hazards. U.S. Coast Guard, 1984.
U.S. Department of Transportation. CHRIS: Manual II, Hazardous Chemical Data.
U.S. Coast Guard, 1984.
U.S. Department of Transportation. Emergency Response Guidebook. Washington
DC: 1984.
U.S. Environmental Protection Agency. Community Relations in Superfund: A Hand-
book. Washington, DC.
U.S. Environmental Protection Agency. The National Oil and Hazardous Substances
Pollution Contingency Plan. 40 CFR 300.
Verschuaren, Karel. Handbook of Environmental Data on Organic Chemicals. 2nd ed.
New York: Van Nostrand Reinhold, 1983.
Waste Resource Associates, Inc. Hazmat - Phases I, II, III, IV: Demonstration Project
to Develop a Hazardous Materials Accident Prevention and Emergency Response Pro-
gram. Niagara Falls, NY: 1983.
Zajic, J.E. and W.A. Himmelman. Highly Hazardous Material Spills and Emergency
Planning. Dekker, 1978.
Transportation Emergency Planning
American Trucking Associations. Handling Hazardous Materials. Washington, DC:
1980.
Association of American Railroads. Emergency Action Guides. Washington, DC: 1984.
Association of American Railroads. Emergency Handling of Hazardous Materials In Sur-
face Transportation. Washington, DC: 1981.
Battelle Pacific Northwest Laboratories. Hazardous Material Transportation Risks in the
Puget Sound Region. Seattle, WA: 1981.
Portland Office of Emergency Management. Establishing Routes for Trucks Hauling
Hazardous Materials: The Experience in Portland, Oregon. Portland, Oregon; 1984.
Portland Office of Emergency Management. Hazardous Materials Highway Routing
Study: Final Report. Portland, OR: 1984.
Russell, E.R., J.J. Smaltz, et al. A Community Model for Handling Hazardous Materi-
als Transportation Emergencies: Executive Summaries. Washington, DC: U.S. Depart-
ment of Transportation, January 1986.
Russell, E.R., J.J. Smaltz, et al. Risk Assessment/Vulnerability Users Manual for Small
Communities and Rural Areas. Washington, DC: U.S. Department of Transportation,
March 1986.
Russell, E.R., W. Brumgardt, et al. Risk Assessment/Vulnerability Validation Study Vol-
ume 2: 11 Individual Studies. Washington, DC: U.S. Department of Transportation,
June 1983.
Page E-3
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Urban Consortium Transportation Task Force. Transportation of. Hazardous Materials.
Washington, DC: U.S. Department of Transportation, September 1980.
Urban Systems Associates, Inc., St. Bernard Parish Planning Commission. St. Bernard
Parish: Hazardous Materials Transportation and Storage Study! New Orleans, LA:
1981. :
Urganek, G. and E. Barber. Development of Criteria to Designate Routes for Transporting
Hazardous Materials. Springfield, VA: National Technical Information Service, 1980.
U.S. Department of Transportation. Community Teamwork: Working Together to Promote
Hazardous Materials Transportation Safety. Washington, DC: 1983.
U.S. Department of Transportation. A Guide for Emergency Highway Traffic Regulation.
Washington, DC: 1985.
U.S. Department of Transportation. A Guide to the Federal Hazardous Transportation
Regulatory Program. Washington, DC: 1983. •
U.S. Department of Transportation. Guidelines for Selecting Preferred Highway Routes for
Highway Route Controlled Quantity Shipments of Radioactive Materials. Washington, DC:
1984. |
I
U.S. Department of Transportation and U.S. Environmental Protection Agency. Lessons
Learned from State and Local Experiences in Accident Prevention and Response Planning
for Hazardous Materials Transportation. Washington, DC, December 1985.
U.S. Department of Transportation. Three-Phase/Four-Volume report: Volume I, A
Community Model for Handling Hazardous Materials Transportation Emergencies; Volume
II, Risk Assessment Users Manual for Small Communities and Rural Areas; Volume III,
Risk Assessment/Vulnerability Model Validation; and, Volume IV, Manual for Small Towns
and Rural Areas to Develop A Hazardous Materials Emergency Plan. 7/81 - 12/85. Docu-
ment is available to the U.S. Public through the National Technical Information Service,
Springfield, VA. 22161. •
Transportation Research Board. Transportation of Hazardous Materials: Toward a National
Strategy. Volumes 1 & 2. Washington, DC: 1983. '
Spill Containment and Cleanup !
Guswa, J.H. Groundwater Contamination and Emergency Response Guide. Noyes, 1984.
U.S. Environmental Protection Agency. Sfafe Participation in the Superfund Remedial Pro-
gram. Washington, DC: 1984. \
I
Personal Protection >
International Association of Fire Chiefs. Fire Service Emergency Management Hand-
book. Washington, DC: 1985. '
National Institute of Occupational Safety and Health. Occupational Safety and Health
Guidance Manual for Hazardous Waste Site Activities. Washington, DC: DHHS Publica-
tion No. 85-115, 1985.
U.S. Environmental Protection Agency. Standard Operating Safety Guides. Washing-
ton, DC: 1984.
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VIDEOTAPES
The following videotapes are available from the Chemical Manufacturers Association:
D CAER: "Reaching Out"
D CAER: "How a Coordinating Group Works"
D CAER: "Working with the Media"
D CAER: "Planning and Conducting Emergency Exercises"
D NCRIC: "First on the Scene"
The following videotapes are available from FEMA's National Emergency Training Cen-
ter/Learning Resource Center/Emergency Management Information Center:
D "Livingston, LA, Hazardous Materials Spills" (September 28, 1982)
O "Waverly, TN, Hazardous Materials Blast" (February 22, 1978)
Also available for purchase from FEMA's National Emergency Training Center (see p.
F-1 for address and telephone number) are videotapes of teleconferences produced
by FEMA's Emergency Education Network (EENET). One available teleconference is:
D "Emergency Exercises — Getting Involved in Community Preparedness," origi-
nally seen on December 11, 1986, and co-sponsored by FEMA, EPA, DOT/
RSPA, USCG, and CMA.
The following documentary videotape (produced by the League of Women Voters of
California and available from Bullfrog Films, Oley PA, 19547) provides public education
on the nature and need for local emergency planning and hazardous materials data
bases from a citizen's perspective.
D "Toxic Chemicals: Information Is The Best Defense"
Page E-5
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APPENDIX F
FEDERAL AGENCY ADDRESSES
1. NATIONAL OFFICES
Federal Emergency Management Agency
Technological Hazards Division
Federal Center Plaza
500 C Street, S.W.
Washington, DC 20472
(202) 646-2861
FEMA National Emergency Training Center
Emmitsburg, MD 21727
(301) 447-6771
U.S. Environmental Protection Agency
OSWER Preparedness Staff
401 M Street, S.W.
Washington, DC 20460
(202) 475-8600
CEPP Hotline: 1-800-535-0202
(479-2449 in Washington, DC area)
U.S. Environmental Protection Agency
OERR Emergency Response Division
401 M Street, S.W.
Washington, DC 20460
(202) 475-8720
Agency for Toxic Substances
and Disease Registry
Department of Health & Human Services
Chamblee Building SOS
Atlanta, GA 30333
(404) 452-4100
U.S. Department of Energy
1000 Independence Avenue, S.W.
Washington, DC 20585
(202) 252-5000
Department of Labor
Occupational Safety & Health Admin.
Directorate of Field Operations
200 Constitution Avenue, N.W.
Washington, DC 20210
(202) 523-7741
U.S. Coast Guard (G-MER)
Marine Environmental Response Division
2100 2nd Street, S.W.
Washington, DC 20593
(202) 267-2010 (info.)
NATIONAL RESPONSE CENTER:
1-800-424-8802
(202-426-2675 or 202-267-2675 in
Washington, DC area)
U.S. Dept. of Transportation
Research and Special Programs Admin.
Office of Hazardous Materials
Transportation (Attention: DHM-50)
400 7th Street, S.W.
Washington, DC 20590
(202) 366-4000
Department of Justice
Environmental Enforcement Section
Room 7313
10th and Constitution, N.W.
Washington, DC 20530
(202) 633-3646
Department of the Interior
18th and C St., N.W.
Washington, DC 20240
(202)343-3891
Department of Agriculture
Forest Service
P.O. Box 96090
Washington, DC 20013-6090
(703) 235-8019
Page F-l
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Department of Commerce Department of State
NOAA — Superfund Program Coordinator Office of Oceans and Polar Affairs
11400 Rockville Pike Room 5801 \
RockviHe, MD 20852 2201 C St., N.W.
(301) 443-8465 Washington, DC 20520
(202) 647-3263
Department of Defense
OASD (A+L)E Nuclear Regulatory Commision
Room 3D 833 Washington, DC ; 20555
The Pentagon (301)492-7000:
Washington, DC 20301-8000
(202) 695-7820
Page F-2
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2. REGIONAL OFFICES
EPA, FEMA, HHS, ATSDR, OSHA
Regional Offices
U.S. COAST GUARD DISTRICTS
Pacific Area ,
COMPACAREA/
/
14th District/
.-Honolulu /
Atlantic Area
COMPLANTAREA
. __ast Guard
Headquarters
Page F-3
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REGIONAL OFFICES
Department of Energy Regional
Coordinating Offices for Radiological Assistance
and Geographical Areas of Responsibility
United States Nuclear Regulatory Commission
Page F-4
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2. REGIONAL OFFICES
(Note:
A. EPA Regional Offices
Direct all requests to the "EPA Regional Preparedness Coordinator" (RFC)
of the appropriate EPA Regional office.)
Region I
(Connecticut, Maine,, Massachusetts,
New Hampshire, Rhode Island, Vermont)
John F. Kennedy Building, Rm. 2203
Boston, MA 02203
(617) 565-3715
RPC: (617) 861-6700
Region II
(New Jersey, New York, Puerto Rico,
Virgin Islands)
26 Federal Plaza, Room 900
New York, NY 10278
(212) 264-2525
RPC: (201) 321-6657
Region III
(Delaware, Washington DC, Maryland,
Pennsylvania, Virginia, West Virginia)
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-9800
RPC: (215) 597-8907
Region VI
(Arkansas, Louisiana, New Mexico,
Oklahoma, Texas)
1445 Ross Avenue, 12th Floor
Dallas, TX 75202-2733
(214) 655-6444
RPC: (214) 655-2270
Region VII
(Iowa, Kansas, Missouri, Nebraska)
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2800
RPC: (913) 236-2806
Region VIII
(Colorado, Montana, North Dakota,
South Dakota, Utah, Wyoming)
One Denver Place
999 18th Street, Suite 1300
Denver, CO 80202-2413
(303) 293-1603
RPC: (303) 293-1723
Region IV
(Alabama, Florida, Georgia, Kentucky,
Mississippi, North Carolina,
South Carolina, Tennessee)
345 Courtland, Street, N.E.
Atlanta, GA 30365
(404) 347-4727
RPC: (404) 347-3931
Region V
(Illinois, Indiana, Michigan,
Minnesota, Ohio, Wisconsin)
230 S. Dearborn Street
Chicago, IL 60604
(312) 353-2000
RPC: (312) 886-1964
Region IX
(Arizona, California, Hawaii, Nevada,
American Samoa, Guam)
215 Fremont Street
San Francisco, CA 94105
(415) 974-8071
RPC: (415) 974-7460
Region X
(Alaska, Idaho, Oregon, Washington)
1200 6th Avenue
Seattle, WA 98101
(206) 442-5810
RPC: (206) 442-1263
Page F-5
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(Note:
B. FEMA Regional Offices
Direct all requests to the "Hazmat Program Staff" of, the appropriate FEMA
Regional office.)
Region I
(Connecticut, Maine, Massachusetts,
New Hampshire, Rhode Island, Vermont)
442 J.W. McCormack POCH
Boston, MA 02109
(617) 223-9540
Region II
(New Jersey, New York, Puerto Rico,
Virgin Islands)
Room 1337
26 Federal Plaza
New York, NY 10278
(212) 264-8980
Region III
(Delaware, Washington DC, Maryland,
Pennsylvania, Virginia, West Virginia)
Liberty Square Building
105 S. 7th Street
Philadelphia, PA 19106
(215) 597-9416
Region IV
(Alabama, Florida, Georgia, Kentucky,
Mississippi, North Carolina,
South Carolina, Tennessee)
Suite 700
1371 Peachtree Street, N.E.
Atlanta, GA 30309
(404) 347-2400
Region V
(Illinois, Indiana, Michigan,
Minnesota, Ohio, Wisconsin)
24th Floor
300 S. Wacker Drive
Chicago, IL 60606
(312) 353-8661
Region VI
(Arkansas, Louisiana, New Mexico,
Oklahoma, Texas)
Federal Regional Center, Room 206
800 N. Loop 288
Denton, TX 76201-3698
(817) 387-5811
Region VII
(Iowa, Kansas, Missouri, Nebraska)
911 Walnut Street, Room 300
Kansas City, MO ! 64106
(816) 374-5912 ;
Region VIII
(Colorado, Montana, North Dakota,
South Dakota, Utah, Wyoming)
Denver Federal Center, Building 710
Box 25267 ;
Denver, CO 80225-0267
(303) 235-4811 !
Region IX
(Arizona, California, Hawaii, Nevada,
American Samoa, Guam)
Building 105
Presidio of San Francisco, CA 94129
(415) 923-7000
Region X
(Alaska, Idaho, Oregon, Washington)
Federal Regional Center
130 228th St., S.W.
Bothell, WA 98021-9796
(206) 481-8800
Page F-6
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C. HHS REGIONAL OFFICES
(Note: Consult the map on Page F-3 to determine which States are assigned to each
Region.)
Region I
Division of Preventive Health Services
John Fitzgerald Kennedy Building
Boston, Massachusetts 02203
(617) 223-4045
Region II
Division of Preventive Health Services
Federal Building
26 Federal Plaza, Room 3337
New York, New York 10278
(212) 264-2485
Region III
Division of Preventive Health Services
Gateway Building #1
Post Office Box 13716
Philadelphia, Pennsylvania 19101
(215) 596-6650
Region IV
Division of Preventive Health Services
101 Marietta Tower
Atlanta, Georgia 30323
(404) 331-2313
Region V
Division of Preventive Health Services
300 South Wacker Drive
Chicago, Illinois 60606
(312) 353-3652
Region VI
Division of Preventive Health Services
1200 Main Tower Building, Room 1835
Dallas, Texas 75202
(214) 767-3916
Region VII
Division of Preventive Health Services
601 East 12th Street
Kansas City, Missouri 64106
(816) 374-3491
Region VIII
Division of Preventive Health Services
1185 Federal Building
1961 Stout Street
Denver, Colorado 80294
(303) 844-6166, ext. 28
Region IX
Division of Preventive Health Services
50 United Nations Plaza
San Francisco, California 94102
(415) 556-2219
Region X
Division of Preventive Health Services
2901 Third Avenue, M.S. 402
Seattle, Washington 98121
(206) 442-0502
Page F-7
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D. ATSDR PUBLIC HEALTH ADVISORS ASSIGNED TO
EPA REGIONAL OFFICES
(Note: Consult the map on Page F-3 to determine which States are assigned to each
Region.) I
Region I
ATSDR Public Health Advisor
EPA Superfund Office
Room 1903
John F. Kennedy Building
Boston, MA 02203
(617)861-6700
Region II
ATSDR Public Health Advisor
Emergency & Remedial Response
Room 737
26 Federal Plaza
New York, New York 10007
(212) 264-8676
Region III
ATSDR Public Health Advisor
EPA Superfund Office
841 Chestnut Street, 6th Floor
Philadelphia, PA 19106
(215) 597-7291
Region IV
ATSDR Public Health Advisor
Air & Waste Management Division
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-3931/2
Region V
ATSDR Public Health Advisor
Emergency & Remedial Branch (5HR)
230 S. Dearborn
Chicago, IL 60604
(312) 886-9293
Region VI
ATSDR Public Health Advisor
EPA Superfund Office
1201 Elm Street
Dallas, TX 75270
(214) 767-9872 ;
Region VII
ATSDR Public He.alth Advisor
Waste Management Branch
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2856;
Region VIII |
ATSDR Public Health Advisor
Waste Management Division
1860 Lincoln Street
Denver, CO 80295
(303) 293-1526
Region IX
ATSDR Public Health Advisor
Toxics & Waste Management Division
215 Freemont Street
San Francisco, CA 94105
(415) 974-7742 ',
Mailing address:! P.O. Box 2453
Daly City, CA 94017
Region X
ATSDR Public Health Advisor
Hazardous Waste (M/S 525)
1200 6th Avenue
Seattle, WA 98101
(206) 442-2711
Page F-8
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E. OSHA REGIONAL OFFICES
(Note: Consult the map on Page F-3 to determine which States are assigned to each
Region.)
Region I
16-18 North Street - 4th Floor
1 Dock Square Building
Boston, Massachusetts 02109
(617) 223-6710
Region II
1515 Broadway (1 Astor Plaza)
Room 3445
New York, New York 10036
(212) 944-3432
Region III
Gateway Building - Suite 2100
3535 Market Street
Philadelphia, Pennsylvania 19104
(215) 596-1201
Region IV
1375 Peachtree Street, N.E.
Suite 587
Atlanta, Georgia 30367
(404) 347-3573
Region V
32nd Floor - Room 3244
230 Dearborn Street
Chicago, Illinois 60604
(312) 353-2220
Region VI
525 Griffin Street
Room 602
Dallas, Texas 75202
(214) 767-4731
Region VII
911 Walnut Street
Room 406
Kansas City, Missouri 64106
(816) 374-5861
Region VIII
Federal Building - Room 1576
1961 Stout Street
Denver, Colorado 80294
(303) 844-3061
Region IX
11349 Federal Building
450 Golden Gate Avenue
P.O. Box 36017
San Francisco, California 94102
(415) 556-7260
Region X
Federal Office Building
Room 6003
909 First Avenue
Seattle, Washington 98174
(206) 442-5930
Page F-9
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F. U.S. Coast Guard District Offices
1st District
(Maine, Massachusetts, New York,
New Hampshire, Connecticut,
Rhode Island, Vermont, Northern
Pennsylvania, Northern New Jersey)
Commander (mep)
408 Atlantic Avenue
Boston, MA 02110-2209
(617) 223-8444
2nd District
(Alabama, Arkansas, Colorado, Illinois,
Indiana, Iowa, Kansas, Kentucky,
Minnesota, Mississippi, Missouri,
Nebraska, North Dakota, Ohio,
Western Pennsylvania,
South Dakota, Tennessee
West Virginia, Wyoming)
7th District
(Georgia, Florida, South Carolina,
Puerto Rico, Virgin Islands)
Commander (mep)
Federal Building |
51 S.W. 1st Avenue
Miami, FL 33130
(305) 350-5276 :
8th District
(Alabama, Florida, Georgia, Louisiana,
Mississippi, New Mexico, Texas)
i
Commander (mpes)
Hale Boggs Federal Building
500 Camp Street,
New Orleans, LA 70130
(504) 589-6296!
Commander (meps)
1430 Olive Street
St. Louis, MO 63103
(314) 425-4655
5th District
(Maryland, Delaware, North Carolina,
Southern Pennsylvania,
Southern New Jersey, Virginia)
Commander (mep)
Federal Building
431 Crawford Street
Portsmouth, VA 23705
(804) 398-6638
9th District ;
(Indiana, Illinois,!Michigan, Minnesota,
Ohio, Pennsylvania, New York,
Wisconsin .
i
Commander (mep)
1240 East 9th Street
Cleveland, OH 44199
(216) 522-3918.
11th District
(Arizona, California, Nevada, Utah)
Commander (mep)
Union Bank Builqiing
400 Oceangate;
Long Beach, CA 90822
(213) 590-2301
Page F-10
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F. U.S. Coast Guard District Offices (Continued)
13th District
(Idaho, Montana, Oregon, Washington)
Commander (mep)
Federal Building
915 Second Avenue
Seattle, WA 98174
(206) 442-5850
14th District
(Hawaii, Guam, American Samoa,
Trust Territory of the Pacific Island,Com
monwealth of Northern Mariana Islands)
Commander (mep)
Prince Kalanianaole Federal Building
300 Ala Moana Boulevard, 9th Floor
Honolulu, HI 96850
(808)541-2114
17th District
(Alaska)
Commander (mep)
P.O. Box 3-5000
Juneau, AK 99802
(907) 586-7195
Page F-ll
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G. Department of Energy (DOE) Regional Coordinating Offices For
Radiological Emergency Assistance \Only
Region 1
(Connecticut, Delaware, District of
Columbia, Maine, Maryland,
Massachusetts, New Hampshire, New
Jersey, New York, Pennsylvania,
Rhode Island, Vermont)
Brookhaven Area Office:
Upton, NY 11973
(516) 282-2200
FTS - 666-2200
(312) 972-5731 (off hours)
(Use same 7-digit number for FTS)
Region 2
(Arkansas, Kentucky, Louisiana,
Mississippi, Missouri, Puerto Rico,
Tennessee, Virgin Islands, Virginia,
West Virginia)
Oak Ridge Operations Office:
P.O. Box E
Oak Ridge, TN 37830
(615) 576-1005
FTS 626-1005
Region 3
(Alabama, Canal Zone, Florida,
Georgia, North Carolina,
South Carolina)
Savannah River Operations Office:
P.O. Box A
Aiken, SC 29801
(803) 725-3333
FTS - 239-3333
Region 4
(Arizona, Kansas, New Mexico,
Oklahoma, Texas)
Albuquerque Operations Office:
P.O. Box 5400
Albuquerque, NM 87115
(505) 844-4667
(Use same 7-digit number for FTS)
Region 5
(Illinois, Indiana, Iowa, Michigan,
Minnesota, Nebraska, North Dakota,
Ohio, Sourth Dakota, Wisconsin)
i
Chicago Operations Office:
9800 South Cass Avenue
Argonne, IL 60439
(312) 972-4800 (duty hours)
(Use same 7-digit number for FTS)
(312) 972-5731 (off hours)
Region 6
(Colorado, Idaho, Montana, Utah,
Wyoming)
Idaho Operations Office:
550 Second Street
Idaho Falls, ID 83401
(208) 526-1515
FTS 582-1515 ",
Region 7 |
(California, Hawaii, Nevada)
San Francisco Operatibns Office:
1333 Broadway
Oakland, CA 94612
(415) 273-4237
FTS 537-4237 '
Region 8 :
(Alaska, Oregon, Washington)
Richland Operations Office:
P.O. Box 550
Richland, WA 99352
(509) 373-3800
FTS - 440-3800
Page F-12
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H. Department Of Transportation, Regional Pipeline Offices
Office of Pipeline Safety
Eastern Region, DPS-4, Room 8321
400 7th Street, S.W.
Washington, DC 20590
(202) 366-4585
(Connecticut, Delaware, District of
Columbia, Maine, Maryland, Vermont,
Massachusetts, New Hampshire, New
Jersey, New York, Pennsylvania,
Rhode Island, Virginia, West Virginia,
Puerto Rico)
Office of Pipeline Safety
Southeast Region, DPS-7
2320 La Branch, Room 2116
Houston, Texas 77704
(713) 750-1746
(Arkansas, Louisiana, New Mexico,
Oklahoma, Texas)
Office of Pipeline Safety
Western Region, DPS-8
555 Zang Street, 2nd Floor
Lakewood, Colorado 80228
(303) 235-3424
Office of Pipeline Safety
Southern Region, DPS-5, Ste. 504N.
1720 Peachtree Road, N.W.
Atlanta, Georgia 30309
(404) 347-2632
(Alabama, Florida, Georgia, Kentucky,
North Carolina, South Carolina, Tennessee)
(Arizona, California, Colorado, Idaho,
Montana, Nevada, North Dakota, Oregon,
South Dakota, Utah, Washington,
Wyoming, Alaska, Hawaii)
Office Of Pipeline Safety
Central Region, DPS-6
911 Walnut Street, Room 1811
Kansas City, Missouri 64106
(816) 374-2653
(Iowa, Illinois, Indiana, Kansas, Michigan,
Minnesota, Ohio, Missouri, Nebraska,
Wisconsin)
Page F-13
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/. U.S. Nuclear Regulatory Commission Regional Offices
Region 1
(Connecticut, Delaware, District of
Columbia, Maine, Maryland,
Massachusetts, New Hampshire, New
Jersey, New York, Pennsylvania,
Rhode Island, Vermont)
USNRC
631 Park Avenue
King of Prussia, PA 19406
(215) 337-5000
Region 2
(Alabama, Florida, Georgia, Kentucky,
Mississippi, North Carolina, Puerto Rico,
South Carolina, Tennessee, Virginia,
Virgin Islands, West Virginia)
USNRC
Suite 2900
101 Marietta Street, NW
Atlanta, GA 30323
(404) 331-4503
Region 3
(Illinois, Indiana, Iowa, Michigan,
Minnesota, Missouri, Ohio, Wisconsin)
USNRC
799 Roosevelt Road
Glen Ellyn, IL 60137
(312) 790-5500
Region 4
(Arkansas, Colorado, Idaho, Kansas,
Louisiana, Montana, Nebraska, New
Mexico, North Dakota, Oklahoma,
South Dakota, Texas, Utah, Wyoming)
USNRC
Suite 1000
611 Ryan Plaza Drive
Arlington, TX 76011
(817) 860-8100
i
Region 5
(Alaska, Arizona, California,
Hawaii, Nevadaj, Oregon, Pacific
Trust Territories, Washington)
USNRC
Suite 210 I
1450 Maria Lane
Walnut Creek, CA 94596
(415)943-3700
*U.S. GOVERNMENT PRINTING OFFICE: 1989 617-003/04873
Page F-14
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