NRT-1 Hazardous Materials Emergency Planning Guide March 1987 NATIONAL RESPONSE TEAM ------- The National Response Team (NRT) composed of 14 Federal agencies having major responsibilities in environmental, transportation, emergency man- agement, worker safety, and public health areas is the national body re- sponsible for coordinating Federal planning, preparedness, and response ac- tions related to oil discharges and hazardous substance releases. NRT member agencies are: Environmental Protection Agency (Chair), Depart- ment of Transportation (U.S. Coast Guard) (Vice-chair), Department of Com- merce, Department of the Interior, Department of Agriculture, Department of Defense, Department of State, Department of Justice, Department of Transpor- tation (Research and Special Programs Administration), Department of Health and Human Services, Federal Emergency Management Agency, Department of Energy, Department of Labor, and Nuclear Regulatory Commission. Under the Superfund Amendments and Reauthorization Act of 1986, the NRT is responsible for publishing guidance documents for the preparation and imple- mentation of hazardous substance emergency plans. ------- National Response Team of the National Oil and Hazardous Substances Contingency Plan G-WER/12, 21OO 2nd Street SW, Washington, D.C. 2O593 NRT Environmental Protection Agency United States Coast Guard Department of Commerce Department of Interior Department of Agriculture Department of Defense Department of State Department of Justice Department of Transportation Department of Health and Human Services Federal Emergency Management Agency Department of Energy Department of Labor March 17, 1987 The National Response Team (NRT) Hazardous Materials Emergency Planning Guide is a product of the cooperative efforts of the 14 Federal agencies that constitute the NRT. The guide fulfills a Congressional requirement that the NRT provide unified Federal guidance for hazardous materials emergency planning and presents a Federal con- sensus upon which future guidance, technical assistance, and training will be based. It also reflects many comments and suggestions received on earlier drafts from State and local governments, industry representatives, emergency managers, environmental organizations, and members of the public actively concerned with hazardous materials prepared- ness, response and prevention. This guide is an important step in a program of implementation that will occur at Federal, State and local levels of government throughout the United States. Thank you for your involvement in this important undertaking. We trus^i thisxTdocument will assist you in your efforts. .S. Environmental Protection Agency Chairman National Response Team Capta,ir U.S. Coast Guard Vice-Chairman National Response Team Report Oil and Chemical Spills Toll Free (8OO)424-88O2 ------- NRT-1 Hazardous Materials Emergency Planning Guide March 1987 NATIONAL RESPONSE TEAM (Replaces proposed Hazardous Materials Emergency Planning Guide dated November 1986) ------- Table of Contents PAGE PREFACE i THE BACKGROUND OF THIS GUIDANCE ii CHAPTER 1: INTRODUCTION 1 1.1 The Need for Hazardous Materials Emergency Planning 1 1.2 Purpose of This Guide 1 1.3 How to Use This Guide 2 1.4 Requirements for Planning 4 1.4.1 Federal Requirements 4 1.4.2 State and Local Requirements 8 1.5 Related Programs and Materials 8 1.5.1 FEMA's Integrated Emergency Management System (CPG 1-8) 8 1.5.2 EPA's Chemical Emergency Preparedness Program (CEPP) 8 1.5.3 DOT Materials 9 1.5.4 Chemical Manufacturers Association's Community Awareness and Emergency Response Program (CMA/CAER) 9 CHAPTER 2: SELECTING AND ORGANIZING THE PLANNING TEAM 11 2.1 Introduction 11 2.2 The Planning Team 11 2.2.1 Forming the Planning Team 11 2.2.2 Respect for All Legitimate Interests 12 2.2.3 Special Importance of Local Governments 14 2.2.4 Local Industry Involvement 14 2.2.5 Size of Planning Team 14 2.3 Organizing the Planning Process 14 2.3.1 Selecting a Team Leader 14 ------- Table of Contents (continued) PAGE 2.3.2 Organizing for Planning Team Responsibilities 16 2.4 Beginning to Plan 18 CHAPTER 3: TASKS OF THE PLANNING TEAM 19 3.1 Introduction 19 3.2 Review of Existing Plans 19 3.3 Hazards Analysis: Hazards Identification, Vulnerability Analysis, Risk Analysis .. 20 3.3.1 Developing the Hazards Analysis 21 3.3.2 Obtaining Facility Information 24 3.3.3 Example Hazards Analysis 25 3.4 Capability Assessment 28 3.4.1 Facility Resources 28 3.4.2 Transporter Resources 31 3.4.3 Community Resources 32 3.5 Writing an Emergency Plan 34 CHAPTER 4: DEVELOPING THE PLAN 35 4.1 Introduction 35 4.2 Hazardous Materials Appendix to Multi-Hazard EOP 35 4.3 Single-Hazard Emergency Plan 36 CHAPTER 5: HAZARDOUS MATERIALS PLANNING ELEMENTS 39 5.1 Introduction 39 5.2 Discussion of Planning Elements 40 CHAPTER 6: PLAN APPRAISAL AND CONTINUING PLANNING 67 6.1 Introduction 67 6.2 Plan Review and Approval 67 6.2.1 Internal Review 67 6.2.2 External Review 67 ------- Table of Contents (Continued) PAGE 6.2.3 Plan Approval 68 6.3 Keeping the Plan Up-to-Date 69 6.4 Continuing Planning 70 6.4.1 Exercises 70 6.4.2 Incident Review 71 6.4.3 Training 71 APPENDICES APPENDIX A: IMPLEMENTING TITLE III: EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW; SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 APPENDIX B: LIST OF ACRONYMS AND RECOGNIZED ABBREVIATIONS APPENDIX C: GLOSSARY APPENDIX D: CRITERIA FOR ASSESSING STATE AND LOCAL PREPAREDNESS APPENDIX E: BIBLIOGRAPHY APPENDIX F: FEDERAL AGENCY ADDRESSES EXHIBITS Exhibit 1: Overview of Planning Process 3 Exhibit 2: Potential Members of an Emergency Planning Team 13 Exhibit 3: Example Hazards Analysis for a Hypothetical Community 26 Exhibit 4: Sample Outline of a Hazardous Materials Emergency Plan 37 Exhibit 5: Key Title III Dates A-10 Exhibit 6: Title III Major Information Flow/Requirements A-11 Exhibit 7: Information from Facilities Provided by Title III in Support of LEPC Plan Development A-12 Exhibit 8: Title III Chemical Lists and Their Purposes A-13 ------- Preface All over America, large and small commu- nities are learning about hazardous mate- rials nearby. Trains derail. Trucks over- turn. Pipelines rupture. Chemical plants have accidental leaks and releases. This guidance will help local communities prepare for potential incidents involving hazardous materials. Some communities already have integrated multi-hazard plans; other communities are only now beginning to plan. This guidance de- scribes how to form a local planning team, find a team leader, identify and analyze hazards, identify existing response equip- ment and personnel, write a plan, and keep a plan up to date. This guidance can be used both by local communities developing their own plan, and by local emergency planning commit- tees formed in accord with the "Emer- gency Planning and Community Right-to- Know Act of 1986." This legislation makes it mandatory for local emergency planning committees to prepare an emergency plan for possible releases of hazardous substances, and for fixed facilities to co- operate in this planning process. A de- tailed summary of this legislation appears in Appendix A; the legislation is refer- enced throughout this guide. Information gathered during the planning process will help communities take steps to make the impact of incidents less se- vere. Improved warning systems, in- creased hazardous materials training of industry and local response personnel, and other efforts at the local level, can all make a community better prepared to prevent and respond to hazardous materi- als incidents. Each community must plan according to its own situation: D The size of the community (smaller communities might have fewer hazards, but also fewer planning and response re- sources for the hazards they do have); D The level of danger (small com- munities are sometimes sur- rounded by large industry); and D Preparedness for planning (some communities have active planning agencies, but other communities have yet to form their first planning committee). There is no single right way to write a plan. This guidance presents a compre- hensive approach to planning. Small communities with few planning resources, or communities with few or no threatening hazards, can choose the planning ele- ments appropriate to their circumstances. Every community, however, should evalu- ate its preparedness for responding to a hazardous materials incident, and plan ac- cordingly. Fourteen Federal agencies have cooper- ated to produce this guidance. We have tried to make this guide consistent with other guides you might use during the planning process. We hope that this uni- fied approach will help your community. ------- The Background of This Guidance This Hazmat Emergency Planning Guide has been developed cooperatively by 14 Federal agencies. It is being published by the National Response Team in compli- ance with Section 303(f) of the "Emer- gency Planning and Community Right-to- Know Act of 1986," Title III of the "Super- fund Amendments and Reauthorization Act of 1986" (SARA). This guide replaces the Federal Emer- gency Management Agency's (FEMA) Planning Guide and Checklist for Hazard- ous Materials Contingency Plans (popu- larly known as FEMA-10). This guide also incorporates material from the U.S. Environmental Protection Agen- cy's (EPA) interim guidance for its Chemi- cal Emergency Preparedness Program (CEPP) published late in 1985. Included are Chapters 2 ("Organizing the Commu- nity"), 4 ("Contingency Plan Development and Content"), and 5 ("Contingency Plan Appraisal and Continuing Planning"). EPA is revising and updating CEPP technical guidance materials that will include site- specific guidance, criteria for identifying extremely hazardous substances, and chemical profiles and a list of such sub- stances. Planners should use this gen- eral planning guide in conjunction with the CEPP materials. In recent years, the U.S. Department of Transportation (DOT) has been active in emergency planning. The Research and Special Programs Administration (RSPA) has published transportation-related re- ports and guides and has contributed to this general planning guide. The U.S. Coast Guard (USCG) has actively imple- mented planning and response require- ments of the National Contingency Plan (NCP), and has contributed to this general planning guide. The U.S. Occupational Safety and Health Administration (OSHA) and the U.S. Agency for Toxic Substances and Disease Registry (ATSDR) have assisted in prepar- ing this general planning guide. In addition to its FEMA-10, FEMA has de- veloped and published a variety of plan- ning-related materials. Of special interest here is Guide for Development of State and Local Emergency Operations Plans (known as CPG 1-8) that encourages communi- ties to develop multi-hazard emergency operations plans (EOPs) covering all haz- ards facing a community (e.g., floods, earthquakes, hurricanes, as well as haz- ardous materials incidents). This general planning guide complements CPG 1-8 and indicates in Chapter 4 how hazardous ma- terials planners can develop or revise a multi-hazard EOP. Chapter 4 also de- scribes a sample outline for an emer- gency plan covering only hazardous mate- rials, if a community does not have the resources to develop a multi-hazard EOP. The terms "contingency plan," "emer- gency plan," and "emergency operations plan" are often used interchangeably, de- pending upon whether one is reading the NCP, CPG 1-8, or other planning guides. This guide consistently refers to "emer- gency plans" and "emergency planning." This guide will consistently use "hazard- ous materials" when generally referring to hazardous substances, petroleum, natu- ral gas," synthetic gas, acutely toxic chemicals, and other toxic chemicals. Ti- tle III of SARA uses the term "extremely hazardous substances" to indicate those chemicals that could cause serious irre- versible health effects from accidental re- leases. The major differences between this docu- ment and other versions proposed for re- view are the expansion of the hazards analysis discussion (Chapter 3) and the addition of Appendix A explaining the plan- ning provisions of Title III of SARA. * We recognize that natural gas is under a specific statute, but because this is a gen- eral planning guide (and because criteria for the list of extremely hazardous sub- stances under Title III of SARA may be ex- panded to include flammability), local planners may want to consider natural gas. ------- 1. Introduction 1.1 The Need for Hazardous Materials Emergency Planning Major disasters like that in Bhopal, India, in December 1984, which resulted in 2,000 deaths and over 200,000 injuries, are rare. Reports of hazardous materials spills and releases, however, are increas- ingly commonplace. Thousands of new chemicals are developed each year. Citi- zens and officials are concerned about accidents (e.g., highway incidents, ware- house fires, train derailments, industrial incidents) happening in their communi- ties. Recent evidence shows that hazard- ous materials incidents are considered by many to be the most significant threat fac- ing local jurisdictions. Ninety-three per- cent of the more than 3,100 localities completing the Federal Emergency Man- agement Agency's (FEMA) Hazard Identi- fication, Capability Assessment, and Multi-Year Development Plan during fiscal year 1985 identified one or more hazard- ous materials risks (e.g., on highways and railroads, at fixed facilities) as a significant threat to the community. Communities need to prepare themselves to prevent such incidents and to respond to the acci- dents that do occur. Because of the risk of hazardous materi- als incidents and because local govern- ments will be completely on their own in the first stages of almost any hazardous materials incident, communities need to maintain a continuing preparedness ca- pacity. A specific, tangible result of being prepared is an emergency plan. Some communities might have sophisticated and detailed written plans but, if the plans have not recently been tested and re- vised, these communities might be less prepared than they think for a possible hazardous materials incident. 1.2 Purpose of This Guide The purpose of this guide is to assist com- munities in planning for hazardous materi- als incidents. "Communities" refers primarily to local ju- risdictions. There are other groups of people, however, that can profitably use this guide. Rural areas with limited re- sources may need to plan at the county or Regional level. State officials seeking to develop a State emergency plan that is closely coordinated with local plans can adapt this guidance to their purposes. Likewise, officials of chemical plants, rail- road yards, and shipping and trucking companies can use this guidance to coor- dinate their own hazardous materials emergency planning with that of the local community. "Hazardous materials" refers generally to hazardous substances, petroleum, natural gas, synthetic gas, acutely toxic chemi- cals, and other toxic chemicals. "Ex- tremely hazardous substances" is used in Title III of the Superfund Amendments and Reauthorization Act of 1986 to refer to those chemicals that could cause serious health effects following short-term expo- sure from accidental releases. The U.S. Environmental Protection Agency (EPA) published an initial list of 402 extremely Page 1 ------- hazardous substances for which emer- gency planning is required. Because this list may be revised, planners should con- tact EPA Regional offices to obtain infor- mation. This guidance deals specifically with response to hazardous materials inci- dentsboth at fixed facilities (manufac- turing, processing, storage, and disposal) and during transportation (highways, wa- terways, rail, and air). Plans for respond- ing to radiological incidents and natural emergencies such as hurricanes, floods, and earthquakes are not the focus of this guidance, although most aspects of plan development and appraisal are common to these emergencies. Communities should see NUREG 0654/FEMA-REP-1 and/or FEMA-REP-5 for assistance in ra- diological planning. (See Appendix C.) Communities should be prepared, how- ever, for the possibility that natural emer- gencies, radiological incidents, and haz- ardous materials incidents will cause or reinforce each other. The objectives of this guide are to: D Focus community activity on emergency preparedness and response; D Provide communities with infor- mation useful in organizing the planning task; D Furnish criteria to determine risk and to help communities decide whether they need to plan for hazardous materials incidents; D Help communities conduct plan- ning that is consistent with their needs and capabilities; and D Provide a method for continually updating a community's emer- gency plan. This guide will not: D Give a simple "fill-in-the- blanks" model plan (because each community needs an emergency plan suited to its own unique circumstances); D Provide details on response techniques; or D Train personnel to respond to in- cidents. Community planners will need to consult other resources in addition to this guide. Related programs and materials are dis- cussed in Section 1.5. 1.3 How to Use This Guide This guide has been designed so it can be used easily by both those communities with little or no planning experience and those communities with extensive plan- ning experience. All planners should consult the decision tree in Exhibit 1 for assistance in using this guide. Chapter 2 describes how communities can organize a planning team. Communi- ties that are beginning the emergency planning process for the first time will need to follow Chapter 2 very closely in order to organize their efforts effectively. Communities with an active planning agency might briefly review Chapter 2, es- pecially to be sure that all of the proper people are included in the planning proc- ess, and move on to Chapter 3 for a de- tailed discussion of tasks for hazardous materials planning. Planners should re- view existing emergency plans, perform a hazards identification and analysis, assess prevention and response capabilities, and then write or revise an emergency plan. Page 2 ------- Exhibit 1 OVERVIEW OF PLANNING PROCESS Determine that a Plan is Needed Select Planning Team Members and Team Leader (See Chapter 2) Begin to Plan Review and Coordinate with Existing Plans (See Chapter 3) Assess Response Capabilities Conduct Hazards Identification and Analysis (See Chapter 3) Assess Industry Response Capabilities (See Chapter 3) Assess Community Response Capabilities (See Chapter 3) Write Plan (See Chapters 4 and 5) Develop or Revise Multi- Hazard Emergency Operations Plan (See Chapter 4) or Develop or Revise Hazardous Materials Emergency Plan (See Chapter 4) Seek Plan Approval Revise, Test, and Maintain Plan (See Chapter 6) Page 3 ------- Chapter 4 discusses two basic ap- proaches to writing an emergency plan: (a) incorporating hazardous materials planning into a multi-hazard emergency operations plan (EOF) (see Section 1.5.1); and (b) developing or revising a plan dealing only with hazardous materi- als. Incorporating hazardous materials planning into a multi-hazard approach is preferable. Some communities, however, have neither the capability nor the re- sources to do this immediately. Commu- nities that choose to develop or revise an EOF should consult FEMA's CFG 1-8 for specific structure requirements for the plan in addition to the discussion in Sec- tion 1.5.1. Communities that choose to develop or revise a single-hazard plan for hazardous materials can use the sample outline of an emergency plan in Chapter 4 to organize the various hazardous materi- als planning elements. (Note: Communi- ties receiving FEMA funds must incorpo- rate hazardous materials planning into a multi-hazard EOF.) Chapter 5 describes the elements to be considered when planning for potential hazardous materials incidents. All com- munities (both those preparing an EOF un- der the multi-hazard approach and those preparing a single-hazard plan) should carefully follow Chapter 5 to ensure that they consider and include the planning elements related to hazardous materials. Chapter 6 describes how to review and update a plan. Experience shows that many communities mistakenly presume that completing an emergency plan auto- matically ensures adequate preparedness for emergency response. All communi- ties should follow the recommendations in Chapter 6 to ensure that emergency plans will be helpful during a real incident. Appendix A is a summary for implement- ing the "Emergency Planning and Com- munity Right-to-Know Act of 1986." Ap- pendix B is a list of acronyms and abbre- viations used in this guidance. Appendix C is a glossary of terms used throughout this guide. (Because this guide neces- sarily contains many acronyms and tech- nical phrases, local planners should regularly consult Appendices B and C.) Appendix D contains criteria for assessing State and local preparedness. Planners should use this appendix as a checklist to evaluate their hazards analysis, the legal authority for responding, the response or- ganizational structure, communication systems, resources, and the completed emergency plan. Appendix E is a list of references on various topics addressed in this guidance. Appendix F is a listing of addresses of Federal agencies at the na- tional and Regional levels. Planners should contact the appropriate office for assistance in the planning process. 1.4 Requirements for Planning Planners should understand Federal, State, and local requirements that apply to emergency planning. 1.4.1 Federal Requirements This section discusses the principal Fed- eral planning requirements found in the National Contingency Plan; Title III of SARA; the Resource Conservation and Re- covery Act; and FEMA's requirements for Emergency Operations Plans. ^- A. National Contingency Plan The National Contingency Plan (NCP), re- quired by section 105 of the Comprehen- sive Environmental Response, Compensa- tion, and Liability Act (CERCLA), calls for extensive preparedness and planning. The National Response Team (NRT), com- prised of representatives of various Fed- eral government agencies with major envi- ronmental, transportation, emergency management, worker safety, and public health responsibilities, is responsible for Page 4 ------- coordinating Federal emergency prepar- edness and planning on a nationwide ba- sis. A key element of Federal support to local responders during hazardous materials transportation and fixed facility incidents is a response by U.S. Coast Guard (USCG) or Environmental Protection Agency (EPA) On-Scene Coordinators (OSCs). The OSC is the Federal official predesignated to coordinate and direct Federal re- sponses and removals under the NCP. These OSCs are assisted by Federal Re- gional Response Teams (RRTs) that are available to provide advice and support to the OSC and, through the OSC, to local responders. Federal responses may be triggered by a report to the National Response Center (NRC), operated by the Coast Guard. Provisions of the Federal Water Pollution Control Act (Clean Water Act), CERCLA ("Superfund"), and various other Federal laws require persons responsible for a dis- charge or release to notify the NRC imme- diately. The NRC Duty Officer promptly relays each report to the appropriate Coast Guard or EPA 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 pre- liminary assessment of the need for a Federal response. This activity may or may not require the OSC or his/her representative to go to the scene of an incident. If an on-scene re- sponse is required, the OSC will go to the scene and monitor the response of the re- sponsible party or State or local govern- ment. If the responsible party is unknown or not taking appropriate action, or the re- sponse is beyond the capability of State and local governments, the OSC may initi- ate Federal actions. The Coast Guard has OSCs at 48 locations (zones) in 10 dis- tricts, and the EPA has OSCs in its 10 Re- gional offices and in certain EPA field of- fices. (See Appendix F for appropriate addresses.) Regional Response Teams are composed of representatives from Federal agencies and a representative from each State within a Federal Region. During a re- sponse to a major hazardous materials in- cident involving transportation or a fixed facility, the OSC may request that the RRT be convened to provide advice or recom- mendations on specific issues requiring resolution. An enhanced RRT role in preparedness activities includes assistance for local community planning efforts. Local emer- gency plans should be coordinated with any Federal Regional contingency plans and OSC contingency plans prepared in compliance with the NCP. Appendix D of this guide contains an adaptation of exten- sive criteria developed by the NRT Prepar- edness Committee to assess State and/or local emergency response preparedness programs. These criteria should be used in conjunction with Chapters 3,4, and 5 of this guide. ^ 8. Title III of SARA ("Superfund Amendments and Reauthorization Act of 1986") Significant new hazardous materials emer- gency planning requirements are con- tained in Title III of SARA (also known as the "Emergency Planning and Community Right-to-Know Act of 1986"). (See Ap- pendix A for a detailed summary on imple- menting Title III.) Title III of SARA requires the establishment of State emergency response commis- sions, emergency planning districts, and local emergency planning committees. The Governor of each State appoints a State emergency response commission whose responsibilities include: designat- ing emergency planning districts; appoint- ing local emergency planning committees for each district; supervising and coordi- nating the activities of planning commit- tees; reviewing emergency plans; receiv- ing chemical release notifications; and es- tablishing procedures for receiving and processing requests from the public for information about and/or copies of emer- gency response plans, material safety data sheets, the list of extremely hazard- ous substances prepared as part of EPA's Page 5 ------- original Chemical Emergency Prepared- ness Program initiative (see Section 1.5.2), inventory forms, and toxic chemi- cal release forms. Forming emergency planning districts is intended to facilitate the preparation and implementation of emergency plans. Planning districts may be existing political subdivisions or multijurisdictional planning organizations. The local emergency plan- ning committee for each district must in- clude representatives from each of the following groups or organizations: D Elected State and local officials; D Law enforcement, civil defense, firefighting, health, local environ- mental, hospital, and transporta- tion personnel; D Broadcast and print media; D Community groups; and D Owners and operators of facili- ties subject to the requirements of Title III of SARA. Each emergency planning committee is to establish procedures for receiving and processing requests from the public for information about and/or copies of emer- gency response plans, material safety data sheets, and chemical inventory forms. The committee must designate an official to serve as coordinator of informa- tion. Facilities are subject to emergency plan- ning and notification requirements if a substance on EPA's list of extremely haz- ardous substances is present at the facil- ity in an amount in excess of the threshold planning quantity for that substance. (See Federal Register, Vol. 51, No. 221, 41570 ef seq.) The owner or operator of each facility subject to these requirements must notify the appropriate State emer- gency response commission that the facil- ity is subject to the requirements. Each facility must also notify the appropri- ate emergency planning committee of a facility representative who will participate in the emergency planning process as a facility emergency coordinator. Upon re- quest, facility owners and operators are to provide the appropriate emergency plan- ning committee with information neces- sary for developing and implementing the emergency plan for the planning district. Title III provisions help to ensure that ade- quate information is available for the plan- ning committee to know which facilities to cover in the plan. (See Appendix A for a discussion of how the local planning com- mittee can use information generated by Title III.) Section 303 (d) (3) requires facil- ity owners and operators to provide to the local emergency planning committee whatever information is necessary for de- veloping and implementing the plan. When there is a release of a chemical identified by Title III of SARA, a facility owner or operator, or a transporter of the chemical, must notify the community emergency coordinator for the emer- gency planning committee for each area likely to be affected by the release, and the State emergency response commis- sion of any State likely to be affected by the release. (This Title III requirement does not replace the legal requirement to notify the National Response Center for releases of CERCLA Section 103 hazard- ous substances.) Each emergency planning committee is to prepare an emergency plan by October 1988 and review it annually. The commit- tee also evaluates the need for resources to develop, implement, and exercise the emergency plan; and makes recommen- dations with respect to additional needed resources and how to provide them. Each emergency plan must include: facilities and transportation routes related to spe- cific chemicals; response procedures of facilities, and local emergency and medi- cal personnel; the names of community and facility emergency coordinators; pro- cedures for notifying officials and the pub- lic in the event of a release; methods for detecting a release and identifying areas and populations at risk; a description of emergency equipment and facilities in the community and at specified fixed facilities; evacuation plans; training programs; and Page 6 ------- schedules for exercising the emergency plan. (These plan requirements are listed in greater detail in Chapter 5.) The com- pleted plan is to be reviewed by the State emergency response commission and, at the request of the local emergency plan- ning committee, may be reviewed by the Federal Regional Response Team. (Note: Many local jurisdictions already have emergency plans for various types of hazards. These plans may only require modification to meet emergency plan re- quirements in Title III of SARA.) Finally, with regard to planning, Title III of SARA requires the NRT to publish guid- ance for the preparation and implementa- tion of emergency plans. This Hazardous Materials Emergency Planning Guide is in- tended to fulfill this requirement. Other Title III provisions supporting emergency planning are discussed in Appendix A. ^ C. Resource Conservation and Recov- ery Act The Resource Conservation and Recovery Act (RCRA) established a framework for the proper management and disposal of all wastes. The Hazardous and Solid Waste Amendments of 1984 (HSWA) ex- panded the scope of the law and placed increased emphasis on waste reduction, corrective action, and treatment of haz- ardous wastes. Under Subtitle C of RCRA, EPA identifies hazardous wastes, both generically and by listing specific wastes and industrial process waste streams; develops stan- dards and regulations for proper manage- ment of hazardous wastes by the genera- tor and transporter, which include a mani- fest that accompanies waste shipments; and develops standards for the treatment, storage, and disposal of the wastes. These standards are generally imple- mented through permits which are issued by EPA or an authorized State. To receive a permit, persons wishing to treat, store, or dispose of hazardous wastes are re- quired to submit permit applications, which must include a characterization of the hazardous wastes to be handled at the facility, demonstration of compliance with standards and regulations that apply to the facility, and a contingency plan. There are required opportunities for public comment on the draft permits, through which local governments and the public may comment on the facility's contin- gency plan. It is important that local emergency response authorities be famil- iar with contingency plans of these facili- ties. Coordination with local community emergency response agencies is required by regulation (40 CFR 264.37), and EPA strongly encourages active community coordination of local response capabilities with facility plans. When a community is preparing an emer- gency plan that includes underground storage tanks (containing either wastes or products), it should coordinate with EPA's Regional offices, the States, and local governments. Underground storage tanks are regulated under Subtitle C or I of RCRA. ^- D. FEMA Emergency Operations Plan Requirements Planning requirements for jurisdictions re- ceiving FEMA funds are set forth in 44 CFR Part 302, effective May 12, 1986. This regulation calls for States and local gov- ernments to prepare an emergency op- erations plan (EOP) which conforms with the requirements for plan content con- tained in FEMA's CPG 1-3, CPG 1-8, and CPG 1-8A. These State and local govern- ment EOPs must identify the available per- sonnel, equipment, facilities, supplies, and other resources in the jurisdiction, and state the method or scheme for coor- dinated actions to be taken by individuals and government services in the event of natural, man-made (e.g., hazardous ma- terials), and attack-related disasters. ^- £. OS HA Regulations Occupational Safety and Health Admini- stration regulations require employers in- volved in hazardous waste operations to develop and implement an emergency re- sponse plan for employees. The ele- ments of this plan must include: (1) rec- Page 7 ------- ognition of emergencies; (2) methods or procedures for alerting employees on site; (3) evacuation procedures and routes to places of refuge or safe dis- tances away from the danger area; (4) means and methods for emergency medi- cal treatment and first aid for employees; (5) the line of authority for employees; (6) on-site decontamination procedures; (7) site control means; and (8) methods for evaluating the plan. Employers whose employees will be responding to hazard- ous materials emergency incidents from their regular work location or duty station (e.g., a fire department, fire brigade, or emergency medical service) must also have an emergency response plan. (See 29 CFR Part 1910.120.) 1.4.2 State and Local Requirements Many States have adopted individual laws and regulations that address local govern- ment involvement in hazardous materials. Local authorities should investigate State requirements and programs before they initiate preparedness and planning activi- ties. Emergency plans should include consideration of any State or local com- munity right-to-know laws. When these laws are more demanding than the Fed- eral law, the State and local laws some- times take precedence over the Federal law. 1.5 Related Programs and Materials Because emergency planning is a com- plex process involving a variety of issues and concerns, community planners should consult related public and private sector programs and materials. The fol- lowing are selected examples of planning programs and materials that may be used in conjunction with this guide. 1.5.1 FEMA's Integrated Emergency Management System (CPG 1-8) FEMA's Guide for Development of State and Local Emergency Operations Plans (CPG 1-8) provides information for emer- gency management planners and for State and local government officials about FEMA's concept of emergency operations planning under the Integrated Emergency Management System (IEMS). IEMS em- phasizes the integration of planning to provide for all hazards discovered in a community's hazards identification proc- ess. CPG 1-8 provides extensive guid- ance in the coordination, development, review, validation, and revision of EOPs (see Section 4.2). (See page F-1 for FEMA's address and telephone number.) This guide for hazardous materials emer- gency planning is deliberately meant to complement CPG 1-8. Chapter 4 de- scribes how a community can incorporate hazardous materials planning into an exist- ing multi-hazard EOP, or how it can de- velop a multi-hazard EOP while address- ing possible hazardous materials inci- dents. In either case, communities should obtain a copy of CPG 1-8 from FEMA and follow its guidance carefully. All communities, even those with sophisti- cated multi-hazard EOPs, should consult Chapter 5 of this guide to ensure ade- quate consideration of hazardous materi- als issues. 1.5.2 EPA's Chemical Emergency Pre- paredness Program (CEPP) In June 1985, EPA announced a compre- hensive strategy to deal with planning for the problem of toxics released to the air. One section of this strategy, the Chemical Emergency Preparedness Program (CEPP), was designed to address acci- dental releases of acutely toxic chemi- cals. This program has two goals: to in- crease community awareness of chemical hazards and to enhance State and local emergency planning for dealing with chemical accidents. Many of the CEPP goals and objectives are included in Title III of SARA (see Section 1.4.1). EPA's CEPP materials (including technical guid- ance, criteria for identifying extremely Page 8 ------- hazardous substances, chemical profiles and list) are designed to complement this guidance and to help communities per- form hazards identification and analysis as described in Chapter 3 of this guide. CEPP materials can be obtained by writing EPA. (See page F-1.) 1.5.3 DOT Materials The U.S. Department of Transportation's (DOT) Community Teamwork is a guide to help local communities develop a cost- effective hazardous materials transporta- tion safety program. It discusses hazards assessment and risk analysis, the devel- opment of an emergency plan, enforce- ment, training, and legal authority for planning. Communities preparing an emergency plan for transportation-related hazards might use Community Teamwork in conjunction with this guide. Lessons Learned is a report on seven haz- ardous materials safety planning projects funded by DOT. The projects included lo- cal plans for Memphis, Indianapolis, New Orleans, and Niagara County (NY); Re- gional plans for Puget Sound and the Oak- land/San Francisco Bay Area; and a State plan for Massachusetts. The Lessons Learned report synthesizes the actual ex- periences of these projects during each phase of the planning process. A major conclusion of this study was that local po- litical leadership and support from both the executive and legislative branches are important factors throughout the planning process. Chapter 2 of this guide incorpo- rates portions of the experiences and con- clusions from Lessons Learned. DOT's Emergency Response Guidebook provides guidance for firefighters, police, and other emergency services personnel to help them protect themselves and the public during the initial minutes immedi- ately following a hazardous materials inci- dent. This widely used guidebook is keyed to the identification placards re- quired by DOT regulations to be displayed prominently on vehicles transporting haz- ardous materials. All first responders should have copies of the Emergency Re- sponse Guidebook and know how to use it. DOT has also published a four-volume guide for small towns and rural areas writ- ing a hazardous materials emergency plan. DOT's objectives were to alert offi- cials of those communities to the threat to life, property, and the environment from the transportation of hazardous materials, and to provide simplified guidance for those with little or no technical expertise. Titles of the volumes are: 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 De- velop a Hazardous Materials Emergency Plan. (See Page F-1 for DOT's address and telephone number.) 1.5.4 Chemical Manufacturers Associa- tion's Community Awareness and Emergency Response Program (CMA/CAER) The Chemical Manufacturers Associa- tion's (CMA) Community Awareness and Emergency Response (CAER) program encourages chemical plant managers to take the initiative in cooperating with local communities to develop integrated emer- gency plans for responding to hazardous materials incidents. Because chemical in- dustry representatives can be especially knowledgeable during the planning proc- ess, and because many chemical plant of- ficials are willing and able to share equip- ment and personnel during response op- erations, community planners should seek out local CMA/CAER participants. Even if no such local initiative is in place, commu- nity planners can approach chemical plant managers or contact CMA and ask for as- sistance in the spirit of the CAER pro- gram. Users of this general planning guide might also purchase and use the following three CMA/CAER publications: "Community Awareness and Emergency Response Program Handbook," "Site Emergency Response Planning," and "Community Emergency Response Exercise Program." (See Appendix E for CMA's address.) Page 9 ------- Page 10 ------- 2. Selecting and Organizing the Planning Team 2.1 Introduction This chapter discusses the selection and organization of the team members who will coordinate hazardous materials plan- ning. The guidance stresses that suc- cessful planning requires community in- volvement throughout the process. Enlist- ing the cooperation of all parties directly concerned with hazardous materials will improve planning, make the plan more likely to be used, and maximize the likeli- hood of an effective response at the time of an emergency. Experience shows that plans are not used if they are prepared by only one person or one agency. Emergency response requires trust, co- ordination, and cooperation among re- sponders who need to know who is re- sponsible for what activities, and who is capable of performing what activities. This knowledge is gained only through personal interaction. Working together in developing and updating plans is a major opportunity for cooperative inter- action among responders. (As indicated in Section 1.4.1, Title III of SARA requires Governors to appoint a State emergency response commission that will designate emergency planning districts and appoint local emergency planning committees for each district. The State commission might follow the guidance in this chapter when appointing planning committees.) 2.2 The Planning Team Hazardous materials planning should grow out of a process coordinated by a team. The team is the best vehicle for incorpo- rating the expertise of a variety of sources into the planning process and for produc- ing an accurate and complete document. The team approach also encourages a planning process that reflects the consen- sus of the entire community. Some indi- vidual communities and/or areas that in- clude several communities have formed hazardous materials advisory councils (HMACs). HMACs, where they exist, are an excellent resource for the planning team. 2.2.1 Forming the Planning Team In selecting the members of a team that will bear overall responsibility for hazard- ous materials planning, four considera- tions are most important: D The members of the group must have the ability, commitment, authority, and resources to get the job done; D The group must possess, or have ready access to, a wide range of expertise relating to the community, its industrial fa- cilities and transportation sys- tems, and the mechanics of Page 11 ------- emergency response and re- sponse planning; D The members of the group must agree on their purpose and be able to work cooperatively with one another; and D The group must be representa- tive of all elements of the com- munity with a substantial interest in reducing the risks posed by hazardous materials. A comprehensive list of potential team members is presented in Exhibit 2. In those communities receiving FEMA funds, paid staff may already be in place for emergency operations planning and other emergency management tasks. This staff should be an obvious resource for hazardous materials planning. FEMA has two training courses for the person assigned as the planning team leader and for team members Introduction to Emergency Management, and Emergency Planning. Another course, Hazardous Ma- terials Contingency Planning, is an inter- agency "train-the-trainer" course pre- sented cooperatively by EPA, FEMA, and other NRT agencies. Course materials and the schedule of offerings are available through State emergency management agencies. 2.2.2 Respect for All Legitimate Inter- ests While many individuals have a common in- terest in reducing the risks posed by haz- ardous materials, their differing eco- nomic, political, and social perspectives may cause them to favor different means of promoting safety. For example, people who live near a facility with hazardous ma- terials are likely to be greatly concerned about avoiding any threat to their lives, and are likely to be less intensely con- cerned about the costs of developing ac- cident prevention and response measures than some of the other groups involved. Others in the community are likely to be more sensitive to the costs involved, and may be anxious to avoid expenditures for unnecessarily elaborate prevention and response measures. Also, facility manag- ers may be reluctant for proprietary rea- sons to disclose materials and processes beyond what is required by law. There may also be differing views among the agencies and organizations with emer- gency response functions about the roles they should play in case of an incident. The local fire department, police depart- ment, emergency management agency, and public health agency are all likely to have some responsibilities in responding to an incident. However, each of these organizations might envision a very differ- ent set of responsibilities for their respec- tive agencies for planning or for manage- ment on scene. In organizing the community to address the problems associated with hazardous materials, it is important to bear in mind that all affected parties have a legitimate interest in the choices among planning alternatives. Therefore, strong efforts should be made to ensure that all groups with an interest in the planning process are included. Some interest groups in the community have well-defined political identities and representation, but others may not. Gov- ernment agencies, private industry, envi- ronmental groups, and trade unions at the facilities are all likely to have ready institu- tional access to an emergency planning process. Nearby residents, however, may lack an effective vehicle for institu- tional representation. Organizations that may be available to represent the resi- dents' interests include neighborhood as- sociations, church organizations, and ad hoc organizations formed especially to deal with the risks posed by the presence of specific hazardous materials in a neigh- borhood. Page 12 ------- Exhibit 2 POTENTIAL MEMBERS OF AN EMERGENCY PLANNING TEAM Part A: Experience shows that the following individuals, groups, and agencies should participate in order for a successful plan to be developed: 'Mayor/city manager (or representative) "County executive (or representative)/board of supervisors *State elected officials (or representative) *Fire department (paid and volunteer) *Police department "Emergency management or civil defense agency "Environmental agency (e.g., air and/or water pollution control agency) "Health department "Hospitals, emergency medical service, veterinarians, medical community "Transportation agency (e.g., DOT, port authority, transit authority, bus company, truck or rail companies) "Industry (e.g., chemical and transportation) Coast Guard/EPA representative (e.g., agency response program personnel) Technical experts (e.g., chemist, engineer) "Community group representative "Public information representative (e.g., local radio, TV, press) Part B: Other groups/agencies that can be included in the planning process, depending on the community's individual priorities: Agriculture agency Indian tribes within or adjacent to the affected jurisdiction Public works (e.g., waste disposal, water, sanitation, and roads) Planning department Other agencies (e.g., welfare, parks, and utilities) Municipal/county legal counsel Workers in local facilities Labor union representatives (e.g., chemical and transportation, industrial health units) Local business community Representatives from volunteer organizations (e.g., Red Cross) Public interest and citizens groups, environmental organizations, and representatives of affected neighborhoods Schools or school districts Key representatives from bordering cities and counties State representatives (Governor, legislator's office, State agencies) Federal agency representatives (e.g., FEMA, DOT/RSPA, ATSDR, OSHA) "Required by Title III of SARA Page 13 ------- 2.2.3 Special Importance of Local Gov- ernments For several reasons, local governments have a critical role to play in the devel- opment of emergency preparedness. First, local governments bear major re- sponsibilities for protecting public health and safety; local police and fire depart- ments, for example, often have the lead responsibility for the initial response to in- cidents involving hazardous materials. Second, one of the functions of local gov- ernment is to mediate and resolve the sometimes competing ideas of different interest groups. Third, local governments have the resources to gather necessary planning data. Finally, local governments generally have the legislative authority to raise funds for equipment and personnel required for emergency response. Sup- port from the executive and legislative branches is essential to successful plan- ning. Appropriate government leaders must give adequate authority to those re- sponsible for emergency planning. 2.2.4 Local Industry Involvement Because fixed facility owners and opera- tors are concerned about public health and safety in the event of an accidental release of a hazardous material, and be- cause many facility employees have tech- nical expertise that will be helpful to the planning team, the team should include one or more facility representatives. Title III of SARA requires facility owners or op- erators to notify the emergency planning committee of a facility representative who will participate in the emergency planning process as a facility emergency coordina- tor. In planning districts that include sev- eral fixed facilities, one or more represen- tative facility emergency coordinators could be active members of the planning team. The planning team could consult with the other facility emergency coordi- nators and/or assign them to task forces or committees (see Section 2.3.2). Title III of SARA also requires facilities to submit to the local emergency planning commit- tee any information needed to develop the plan. 2.2.5 Size of Planning Team For the planning team to function effec- tively, its size should be limited to a work- able number. In communities with many interested parties, it will be necessary to select from among them carefully so as to ensure fair and comprehensive represen- tation. Some individuals may feel left out of the planning process. This can be off- set by providing these individuals access to the process through the various ap- proaches noted in the following sections, such as membership on a task force or advisory council. In addition, all inter- ested parties should have an opportunity for input during the review process. 2.3 Organizing the Planning Process After the planning team members have been identified, a team leader must be chosen and procedures for managing the planning process must be established. 2.3.1 Selecting a Team Leader A community initiating a hazardous mate- rials emergency planning process may choose to appoint an individual to facilitate and lead the effort, or may appoint a plan- ning team and have the group decide who will lead the effort. Either approach can be used. It is essential to establish clear responsibility and authority for the project. The chief executive (or whoever initiates the process) should determine which course is better suited to local circum- stances. (The emergency planning com- mittee required by Title III of SARA is to select its own chairperson). Regardless of how the team leader is selected, it is his or her primary responsibility to over- Page 14 ------- see the team's efforts through the entire planning process. Because the role of leader is so significant, a co-chair or back-up could also be named. Five factors are of major importance in selecting a team leader: D The degree of respect held for the person by groups with an in- terest in hazardous materials; D Availability of time and re- sources; D The person's history of working relationships with concerned community agencies and organi- zations; D The person's management and communication skills; and D The person's existing responsi- bilities related to emergency planning, prevention, and re- sponse. Logical sources for a team leader include: D The chief executive or other elected official. Leadership by a mayor, city or county council member, or other senior official is likely to contribute substan- tially to public confidence, en- courage commitment of time and resources by other key par- ties, and expedite the implemen- tation of program initiatives. Discontinuity in the planning process can result, however, if an elected official leaves office. D A public safety department. In most communities, the fire de- partment or police department bears principal responsibility for responding to incidents involving chemical releases and, typically, for inspecting facilities as well. A public safety department, therefore, may have personnel with past experience in emer- gency planning and present knowledge of existing responsi- bilities within the community. D The emergency management or civil defense agency. In many communities, officials of such an agency will be knowl- edgeable and experienced in planning for major disasters from a variety of causes. One of the primary responsibilities of a community's emergency man- agement coordinator is to guide, direct, and participate in the de- velopment of a multi-hazard emergency operations plan. In some States, existing laws re- quire that this agency be the lead agency to prepare and dis- tribute emergency plans. D The local environmental agency or public health agency. Persons with expertise and legal responsibility in these areas will have special knowl- edge about the risks posed by hazardous materials. D A planning agency. Officials in a planning agency will be familiar with the general planning proc- ess and with the activities and resources of the community. D Others. Communities should be creative and consider other pos- sible sources for a team leader, such as civic groups, industry, academic institutions, volunteer organizations, and agencies not mentioned above. Experience in leading groups and committees, regardless of their purpose, will prove useful in emergency plan- ning. Personal considerations as well as institu- tional ones should be weighed in selecting a team leader. For example, a particular organization may appear to have all the right resources for addressing hazardous materials incidents. But if the person in charge of that organization does not inter- act well with other local officials, it might be best to look for a different leader. Page 15 ------- A response coordinator generally is knowl- edgeable about emergency plans and is probably a person who gets things done. Be aware, however, that a good response coordinator is not necessarily a good plan- ner. He or she might make a good chief advisor to someone better suited for the team leader job. 2.3.2 Organizing for Planning Team Re- sponsibilities The planning team must decide who shall conduct the planning tasks and establish the procedures for monitoring and ap- proving the planning tasks. ^ A, Staffing There are three basic staffing approaches that may be employed to accomplish the tasks involved in emergency planning: D Assign staff. Previous experi- ence in related planning efforts demonstrates the usefulness of assigning one or more dedicated staff members to coordinate the planning process and perform specific planning .tasks. The staff may be assigned within a "lead agency" having related re- sponsibilities and/or expertise, or may be created separately through outside hiring and/or staff loans from government agencies or industry. D Assign task forces or commit- tees. Planning tasks can be per- formed by task forces or com- mittees composed entirely or in part of members of the planning team. Adding knowledgeable representatives of government agencies, industry, environ- mental, labor, and other com- munity organizations to the indi- vidual task forces or committees not only supplements the plan- ning team expertise and re- sources, but also provides an opportunity for additional inter- ested parties to participate di- rectly in the process. D Hire contractors or consultants. If the personnel resources avail- able for the formation of a dedi- cated staff and task forces or committees are limited, and funds can be provided, the plan- ning team may elect to hire con- tractors or consultants. Work assigned to a contractor can range from a specialized job, such as designing a survey, to performing an entire planning task (e.g., hazards identification and analysis). A disadvantage of hiring contractors or consult- ants is that it does not help build a community-centered capabil- ity or planning infrastructure. The three approaches presented above are not mutually exclusive. A community may adopt any combination of the ap- proaches that best matches its own cir- cumstances and resources. ^- 8. Managing the Planning Tasks The monitoring and approval of planning assignments are the central responsibili- ties of the planning team. In order to have ongoing cooperation in implementing the plan, it is recommended that the planning team operate on a consensus basis, reaching general agreement by all mem- bers of the team. Achieving consensus takes more time than majority voting, but it is the best way to ensure that all repre- sented parties have an opportunity to ex- press their views and that the decisions represent and balance competing inter- ests. If it is determined that a consensus method is inappropriate or impossible (e.g., because of the multi-jurisdictional nature of a group), the planning team should formally decide how issues will be resolved. The team leader should work with the team members to establish clear goals and deadlines for various phases of the planning process. Progress toward these goals and deadlines should be monitored frequently. Page 16 ------- Planning meetings, a necessary element of the planning process, often do not make the best use of available time. Meetings can be unnecessarily long and unproductive if planning members get bogged down on inappropriate side is- sues. Sometimes, when several agencies or groups sit down at one table, the meet- ing can become a forum for expressing political differences and other grievances fueled by long-standing interagency rival- ries. For a team to be effective, a strong team leader will have to make sure that meeting discussions focus solely on emergency planning. Another point to consider is that the team approach requires the melding of inputs from different individuals, each with a dif- ferent style and sense of priorities. A team leader must ensure that the final plan is consistent in substance and tone. An editor may be used to make sure that the plan's grammar, style, and content all ultimately fit well together. On critical decisions, it may be desirable to extend the scope of participation be- yond the membership of the planning team. Approaches that might be used to encourage community consensus building through broadened participation in the process include invited reviews by key in- terest groups, or formation of an advisory council composed of interested parties that can independently review and com- ment on the planning team's efforts. Chapter 6 contains further guidance on consensus-building approaches. The procedures to be used for monitoring and approving planning assignments should be carefully thought out at the be- ginning of the planning process; planning efforts work best when people understand the ground rules and know when and how they will be able to participate. The moni- toring and approval process can be ad- justed at any time to accommodate vari- ations in local interest. Planning committees formed according to Title III of SARA are to develop their own rules. These rules include provisions for public notification of committee activities; public meeting to discuss the emergency plan; public comments; response to pub- lic comments by the committee; and dis- tribution of the emergency plan. ^- C. The Use of Computers Computers are handy tools for both the planning process and for maintaining re- sponse preparedness. Because new technology is continually being developed, this guide does not identify specific hard- ware or software packages that planning teams and/or response personnel might use. Local planners should consult Re- gional FEMA or EPA offices (see Appendix F) for more detailed descriptions of how some communities are using computers. The following list summarizes some ways in which computers are useful both in the planning process and for maintaining re- sponse preparedness. D Word processing. Preparation and revision of plans is expe- dited by word processing. Of special interest to planners is the use of word processing to keep an emergency plan up to date on an annual or semiannual ba- sis. D Modeling. Planners might con- sider applying air dispersion models for chemicals in their community so that, during an emergency, responders can predict the direction, velocity, and concentration of plume movement. Similarly, models can be developed to predict the pathways of plumes in surface water and ground water. D Information access. Respond- ers can use a personal comput- er on site to learn the identity of the chemical (s) involved in the incident (e.g., when placards are partially covered), the ef- fects of the chemical (s) on hu- man health and the environ- ment, and appropriate counter- measures to contain and clean Page 17 ------- up the chemical (s). Communi- ties that intend to use computers on scene should also provide a printer on scene. D Data storage. Communities can store information about what chemicals are present in various local facilities, and the availabil- ity of equipment and personnel that are needed during re- sponses to incidents involving specific chemical (s). Compli- ance with Title III will generate large amounts of data (e.g., MSDS forms, data on specific chemicals in specific facilities, data on accidental releases). (See Appendix A.) Such data could be electronically stored and retrieved. These data should be reviewed and updated regu- larly. Area maps with informa- tion about transportation and evacuation routes, hospital and school locations, and other emergency-related information, can also be stored in computer disks. State and local planners with personal computer communications capability can access the Federally operated National Hazardous Materials Information Exchange (NHMIE) by dialing (312) 972-3275. Us- ers can obtain up-to-date information on hazmat training courses, planning tech- niques, events and conferences, and emergency response experiences and lessons learned. NHMIE can also be reached through a toll-free telephone call (1-800-752-6367; in Illinois, 1-800-367- 9592). 2.4 Beginning to Plan When the planning team members and their leader have been identified and a process for managing the planning tasks is in place, the team should address sev- eral interrelated tasks. These planning tasks are described in the next chapter. Page 18 ------- 3. Tasks of the Planning Team 3.1 Introduction The major tasks of the planning team in completing hazardous materials planning are: D Review of existing plans, which prevents plan overlap and incon- sistency, provides useful infor- mation and ideas, and facilitates the coordination of the plan with other plans; D Hazards analysis, that includes hazards identification, vulnerabil- ity analysis, and risk analysis; D Assessment of preparedness, prevention, and response capa- bilities, that identifies existing prevention measures and re- sponse capabilities (including mutual aid agreements), and as- sesses their adequacy; D Completion of hazardous mate- rials planning that describes the personnel, equipment, and pro- cedures to be used in case of accidental release of a hazard- ous material; and D Development of an ongoing program for plan implementa- tion/maintenance, training, and exercising. This chapter discusses the planning tasks that are conducted prior to the prepara- tion of the emergency plan. Chapters 4 and 5 provide guidance on plan format and content. Chapter 6 discusses the team's responsibilities for conducting in- ternal and external reviews, exercises, in- cident reviews, and training. This chapter begins with a discussion of the organiza- tional responsibilities of the planning team. 3.2 Review of Existing Plans Before undertaking any other work, steps should be taken to search out and review all existing emergency plans. The main reasons for reviewing these plans are (1) to minimize work efforts by building upon or modifying existing emergency planning and response information and (2) to en- sure proper coordination with other re- lated plans. To the extent possible, cur- rently used plans should be amended to account for the special problems posed by hazardous materials, thereby avoiding redundant emergency plans. Even plans that are no longer used may provide a useful starting point. More general plans can also be a source of information and ideas. In seeking to identify existing plans, it will be helpful to consult organiza- tions such as: D State and local emergency man- agement agencies; D Fire department?; D Police departments; Page 19 ------- D State and local environmental agencies; D State and local transportation agencies; D State and local public health agencies; D Public service agencies; D Volunteer groups, such as the Red Cross; D Local industry and industrial as- sociations; and D Regional offices of Federal agen- cies such as EPA and FEMA. When reviewing the existing plans of local industry and industrial associations, the planning team should obtain a copy of the CAER program handbook produced by CMA. (See Section 1.5.4.) The hand- book provides useful information and en- courages industry-community coopera- tion in emergency planning. In addition to the above organizations, planning teams should coordinate with the RRTs and OSCs described in Section 1.4.1. Communities can contact or obtain information on the RRT and OSC covering their area through the EPA Regional office or USCG district office. (See Appendix F for a list of these contacts.) 3.3 Hazards Analysis: Hazards Identification, Vulnerability Analysis, Risk Analysis A hazards analysis is a critical component of planning for hazardous materials releases. The information developed in a hazards analysis provides both the factual basis to set priorities for planning and also the necessary documentation for supporting hazardous materials planning and response efforts. There are several concepts involved in analyzing the dangers posed by hazardous materi- als. Three terms hazard, vulnerability, risk have different technical meanings but are sometimes used interchangeably. This guidance adopts the following definitions: D Hazard. Any situation that has the potential for causing injury to life, or damage to property and the environment. D Vulnerability. The susceptibility of life, property, and the environment to injury or damage if a hazard manifests its potential. D Risk. The probability that injury to life, or damage to property and the environ- ment will occur. A hazards analysis may include vulnerability analysis and risk analysis, or it may simply identify the nature and location of hazards in the community. Developing a complete hazards analysis that examines all hazards, vulnerabilities, and risks may be neither possi- ble nor desirable. This may be particularly true for smaller communities that have less expertise and fewer resources to contribute to the task. The planning team must deter- mine the level of thoroughness that is appropriate. In any case, planners should ask local facilities whether they have already completed a facility hazards analysis. Title III requires facility owners or operators to provide to local emergency planning committees informa- tion needed for the planning process. Page 20 ------- As important as knowing how to perform a hazards analysis is deciding how detailed an analysis to conduct. While a complete analysis of all hazards would be informative, it may not be feasible or practical given resource and time constraints. The value of a limited hazards analysis should not be underestimated. Often the examination of only major hazards is necessary, and these may be studied without undertaking an elaborate risk analysis. Thus, deciding what is really needed and what can be afforded is an important early step in the hazards analysis process. In fact, the screening of hazards and setting analysis priorities is an essential task of the planning team. The costs of hazards analysis can and often should be reduced by focusing on the haz- ards posed by only the most common and/or most hazardous substances. A small num- ber of types of hazardous materials account for the vast majority of incidents and risk. The experience from DOT'S Lessons Learned is that the most prevalent dangers from hazardous materials are posed by common substances, such as gasoline, other flamma- ble materials, and a few additional chemicals. The CEPP technical guidance presents a method that may be used to assist in ranking hazards posed by less prevalent but ex- tremely hazardous substances, such as liquid chlorine, anhydrous ammonia, and hydro- chloric and sulfuric acids. A hazards analysis can be greatly simplified by using qualitative methods (i.e., analysis that is based on judgment rather than measurement of quantities involved). Smaller com- munities may find that their fire and police chiefs can provide highly accurate assess- ments of the community's hazardous materials problems. Other, larger communities may have the expertise and resources to utilize quantitative techniques but may decide to substitute qualitative methods in their place should it be cost effective to do so. Simple or sophisticated, the hazards analysis serves to characterize the nature of the problem posed by hazardous materials. The information that is developed in the hazards analysis should then be used by the planning team to orient planning appropriate to the community's situation. Do not commit valuable resources to plan development until a hazards analysis is performed. 3.3.1 Developing the Hazards Analysis The procedures that are presented in this section are intended to provide a simplified approach to hazards analysis for both facility and transportation hazards. Communities undertaking a hazards analysis should refer to CEPP technical guidance for fixed facilities and to Lessons Learned and Community Teamwork for transportation. The components of a hazards analysis include the concepts of hazard, vulnerability, and risk. The discussion that follows summarizes the basic procedures for conducting each component. ^ A. Hazards Identification The hazards identification provides information on the facility and transportation situations that have the potential for causing injury to life, or damage to property and the environ- ment due to a hazardous materials spill or release. The hazards identification should indicate: D The types and quantities of hazardous materials located in or transported through a community; Page 21 ------- D The location of hazardous materials facilities and routes; and D The nature of the hazard (e.g., fire, explosions) most likely to accompany haz- ardous materials spills or releases. To develop this information, consider hazardous materials at fixed sites and those that are transported by highway, rail, water, air, and pipeline. Examine hazardous materials at: D Chemical plants; D Refineries; D Industrial facilities; D Petroleum and natural gas tank farms; D Storage facilities/warehouses; D Trucking terminals; D Railroad yards; D Hospital, educational, and governmental facilities; D Waste disposal and treatment facilities; D Waterfront facilities, particularly commercial marine terminals; D Vessels in port; D Airports; D Nuclear facilities; and D Major transportation corridors and transfer points. For individual facilities, consider hazardous materials: D Production; D Storage; D Processing; D Transportation; and D Disposal. Some situations will be obvious. To identify the less obvious ones, interview fire and police chiefs, industry leaders, and reporters; review news releases and fire and police department records of past incidents. Also, consult lists of hazardous chemicals that have been identified as a result of compliance with right-to-know laws. (Title III of SARA requires facility owners and operators to submit to the local emergency planning commit- tee a material safety data sheet for specified chemicals, and emergency and hazardous chemical inventory forms. Section 303 (d) (3) of Title III states that "upon request from the emergency planning committee, the owner or operator of the facility shall promptly provide information... necessary for developing and implementing the emergency plan.") Use the CEPP technical guidance for help in evaluating the hazards associated with air- borne releases of extremely hazardous substances. Page 22 ------- The hazards identification should result in compilation of those situations that pose the most serious threat of damage to the community. Location maps and charts are an excellent means of depicting this information. ^ B. Vulnerability Analysis The vulnerability analysis identifies what in the community is susceptible to damage should a hazardous materials release occur. The vulnerability analysis should provide informa- tion on: D The extent of the vulnerable zone (i.e., the significantly affected area) for a spill or release and the conditions that influence the zone of impact (e.g., size of release, wind direction); D The population, in terms of size and types (e.g., residents, employees, sensi- tive populations hospitals, schools, nursing homes, day care centers), that could be expected to be within the vulnerable zone; D The private and public property (e.g., homes, businesses, offices) that may be damaged, including essential support systems (e.g., water, food, power, medi- cal) and transportation corridors; and D The environment that may be affected, and the impact on sensitive natural areas and endangered species. Refer to the CEPP technical guidance or DOT's Emergency Response Guidebook to obtain information on the vulnerable zone for a hazardous materials release. For information on the population, property, and environmental resources within the vulnerable zone, con- sider conducting: D A windshield survey of the area (i.e., first hand observation by driving through an area); D Interviews of fire, police, and planning department personnel; and D A review of planning department documents, and statistics on land use, popula- tion, highway usage, and the area's infrastructure. The vulnerability analysis should summarize information on all hazards determined to be major in the hazards identification. ^ C. Risk Analysis The risk analysis assesses the probability of damage (or injury) taking place in the com- munity due to a hazardous materials release and the actual damage (or injury) that might occur, in light of the vulnerability analysis. Some planners may choose to analyze worst- case scenarios. The risk analysis may provide information on: D The probability that a release will occur and any unusual environmental condi- tions, such as areas in flood plains, or the possibility of simultaneous emergency incidents (e.g., flooding or fire hazards resulting in release of hazardous materi- . als); D The type of harm to people (acute, delayed, chronic) and the associated high- risk groups; D The type of damage to property (temporary, repairable, permanent); and Page 23 ------- D The type of damage to the environment (recoverable, permanent). Use the Chemical Profiles in the CEPP technical guidance or a similar guide to obtain information on the type of risk associated with the accidental airborne release of ex- tremely hazardous substances. Developing occurrence probability data may not be feasible for all communities. Such analysis can require specialized expertise not available to a community. This is especially true of facility releases which call for detailed analysis by competent safety engineers and others (e.g., industrial hygienists) of the operations and associated risk factors of the plant and engineering system in question (refer to the American Institute of Chemical Engineers' Guidelines for Hazard Evaluation Procedures). Transportation release analysis is more straightforward, given the substantial research and established techniques that have been developed in this area (refer to Community Teamwork and Lessons Learned). Communities should not be overly concerned with developing elaborate quantitative re- lease probabilities. Instead, occurrence probabilities can be described in relative terms (e.g., low, moderate, high). The emphasis should be on developing reasonable esti- mates based on the best available expertise. 3.3.2 Obtaining Facility Information The information that is needed about a facility for hazards analysis may already be assem- bled as a result of previous efforts. As indicated in Section 1.4.1, industry is required by Title III of SARA to provide inventory and release information to the appropriate emergency planning committee. Local emergency planning committees are specifically entitled to any information from facility owners and operators deemed necessary for developing and implementing the emergency plan. The EPA Administrator can order facilities to comply with a local committee's requests for necessary information; local planning committees can bring a civil suit against a facility that refuses to provide requested information. Some State and local governments have adopted community right-to-know legislation. These community right-to-know provisions vary, but they generally require industry and other handlers of hazardous materials to provide information to State or local authorities and/or the public about hazardous materials in the community. Wisconsin, for example, requires all hazardous materials spills to be reported to a State agency. Such requirements pro- vide a data base that the planning team can use to determine the types of releases that have occurred in and around the community. Requesting information from a facility for a hazards analysis can be an opening for con- tinuing dialogue within the community. The information should be sought in such a way that facilities are encouraged to cooperate and participate actively in the planning process along with governmental agencies and other community groups. Respecting a commer- cial facility's needs to protect confidential business information (such as sensitive process information) will encourage a facility to be forthcoming with the information necessary for the community's emergency planning. The planning team can learn what the facility is doing and what measures have been put in place to reduce risks, and also identify what additional resources such as personnel, training, and equipment are needed in the com- munity. Because facilities use different kinds of hazard assessments (e.g., HAZOP, Fault-tree analysis), local planners need to indicate specifically what categories of infor- mation they are interested in receiving. These categories may include: D Identification of chemicals of concern; Page 24 ------- D Identification of serious events that can lead to releases (e. g., venting or sys- tem leaks, runaway chemical reaction); D Amounts of toxic material or energy (e. g., blast, fire radiation) that could be released; D Predicted consequences of the release (e. g., population exposure illustrated with plume maps and damage rings) and associated damages (e. g., deaths, injuries); D Whether the possible consequences are considered acceptable by the facility; and O Prevention measures in place on site. The facilities themselves are a useful resource; the community should work with the facil- ity personnel and utilize their expertise. The assistance that a facility can provide in- cludes: D Technical experts; D Facility emergency plans; D Cleanup and recycling capabilities; D Spill prevention control and countermeasures (SPCC); D Training and safe handling instructions; and D Participation in developing the emergency plan, particularly in defining how to handle spills on company property. Cooperative programs such as CMA's CAER program are also a source for hazard infor- mation. One of the major objectives of the CAER program is to improve local emergency plans by combining chemical plant emergency plans with other local planning to achieve an integrated community emergency plan. The planning team should ask the facility if it is participating in the CAER program; this may stimulate non-CMA members to use the CAER approach. If a facility is participating in the CAER program, the emergency plans developed by the facility will serve as a good starting point in information gathering and emergency planning. The CAER program handbook also encourages companies to per- form hazards analyses of their operations. Local planners should ask facilities if they have adhered to this recommendation and whether they are willing to share results with the planning team. 3.3.3 Example Hazards Analysis Exhibit 3 presents an example of a very simple hazards analysis for a hypothetical com- munity. Hazards A, B, and C are identified as three among other major hazards in the community. Information for the exhibit could have been obtained from windshield surveys of the area; the CEPP technical guidance; information gained from facilities under Title III provisions; and/or interviews with fire, police, county planners, and facility representa- tives. These interviews also could have provided input into the exhibit's qualitative as- sessments of hazard occurrence. Once completed, the hazards analysis is an essential tool in the planning process. It assists the planning team to decide: Page 25 ------- Exhibit 3 EXAMPLE HAZARDS ANALYSIS FOR A HYPOTHETICAL COMMUNITY Hazard A Hazard B Hazard C 1. HAZARDS IDENTIFICATION (MAJOR HAZARDS) a. Chemical b. Location Chlorine Water treatment plant Ammonia Tank truck on local Interstate highway Liquid methyl Isocyanate (MIC) Pesticide manufacturing plant In nearby semi-rural area c. Quantity d. Properties a OQ 2000 Ibs Poisonous; may be fatal if Inhaled. Res- piratory conditions aggravated by expo- sure. Contact may cause burns to skin and eyes. Corrosive. Effects may be delayed. 5000 Ibs Poisonous; may be fatal if Inhaled. Va- pors cause Irritation of eyes and respira- tory tract. Liquid will burn skin and eyes. Contact with liquid may cause frostbite. Effects may be delayed. Will burn within certain vapor concentration limits and Increase fire hazard In the presence of oil or other combustible ma- terials. 5000 Ibs Causes death by respiratory distress af- ter Inhalation. Other health effects would include permanent eye damage, respiratory distress, and disorientation. Explosive. Extremely flammable. 2. VULNERABILITY ANALYSIS Os a. Vulnerable zone b. Population within vulnerable zone A spill of 2000 Ibs of chlorine from a storage tank could result in an area of radius 1650 feet (0.3 miles) where chlo- rine gas may exceed the level of con- cern. Approximately 500 residents of a nurs- ing home; workers at small factory. A spill of 5000 Ibs of ammonia resulting from a collision of a tank truck could re- sult In an area of radius 1320 feet (0.25 miles) where ammonia exceeds its level of concern. Up to 700 persons in residences, com- mercial establishments, or vehicles near highway interchange. Seasonal in- flux of visitors to forest preserve in the fall. A spill of 5000 Ibs of methyl Isocyanate could affect an area of radius 3300 feet (0.6 miles) with MIC vapors exceeding the level of concern (assuming that the liquid is hot when spilled, the tank Is not diked, and the MIC is at 100% concen- tration). Up to 200 workers at the plant and 1000 children in a school. c. Private and public property that may be damaged Facility equipment, vehicles, and struc- tures susceptible to damage from corro- sive fumes. Community's water supply may be temporarily affected given that the facility is its primary supplier. Mix- ture with fuels may cause an explosion. 25 residences, 2 fast food restaurants, one 30 room motel, a truck stop, a gas station and a mini-market. Highway and nearby vehicles may be susceptible to damage from a fire or explosion re- sulting from the collision. Runoff to a sewer may cause an explo- sion hazard as MIC reacts violently with water. d. Environment that may be affected Terrestrial life. Adjacent forest preserve is highly sus- ceptible to forest fires especially during drought conditions. Nearby farm animals. ------- Exhibit 3 (Continued) EXAMPLE HAZARDS ANALYSIS FOR A HYPOTHETICAL COMMUNITY Hazard A Hazard B Hazard C 3. RISK ANALYSIS a. Probability of hazard occurrence Low because chlorine is stored in an area with leak detection equipment in 24 hour service with alarms. Protective equipment is kept outside storage room. High Highway Interchange has a his- tory of accidents due to poor visibility of exits and entrances. Low facility has up to date contain- ment facilities with leak detection equipment, and an emergency plan for its employees. There are good security arrangements that would deter tamper- Ing or accidents resulting from civil up- risings. b. Consequences If people are exposed High levels of chlorine gas in the nursing home and factory could cause death and respiratory distress. Bedridden nursing home patients are especially suscepti- ble. Release of vapors and subsequent fire may cause traffic accidents. Injured and trapped motorists are subject to le- thal vapors and possible Incineration. Windblown vapors can cause respiratory distress for nearby residents and busi- ness patrons. If accident occurs while school Is In ses- sion, children could be killed, blinded, and/or suffer chronic debilitating respi- ratory problems. Plant workers would be subject to similar effects at any time. a 00 X) d. Consequences for property Consequences of environmental exposure Possible superficial damage to facility equipment and structures from corrosive fumes (repairable). Possible destruction fauna and flora. of surrounding Repairable damage to highway. Poten- tial destruction of nearby vehicles due to fire or explosions. Potential for fire damage to adjacent forest preserve due to combustible ma- terial (recoverable in the long term). Vapors may explode In a confined space causing property damage (repairable). Damage could result from fires (repair- able). Farm animals and other fauna could be killed or suffer health effects necessi- tating their destruction or indirectly causing death. Probability of simultaneous emergencies Low High Low f. Unusual environmental conditions None Hilly terrain prone to mists, thus creat- ing adverse driving conditions. Located In a 500 year river flood plan. ------- D The level of detail that is necessary; D The types of response to emphasize; and D Priority hazards or areas for planning. The examples presented in Exhibit 3 illustrate the basic fact that there are no hard and fast rules for weighing the relative importance of different types of hazards in the context of the planning process. Compare example hazards B and C in the exhibit. Hazard C involves a substance, methyl isocyanate (MIC), whose lethal and severe chronic effects were evident at Bhopal. As described in the example, an MIC release could affect 200 plant workers and 1000 children in a nearby school. By contrast, the ammonia in example hazard B is less lethal than MIC and threatens fewer people. With just this information in mind, a planner might be expected to assign the MIC a higher planning priority than he would the ammonia. Consider now the "probability of occurrence." In example C, plant safety and prevention measures are excellent, and an MIC incident is correspondingly unlikely to occur. On the other hand, poor highway construction and weather conditions that affect visibility make an ammonia incident (example hazard B) far more probable. Planners must balance all factors when deciding whether to give planning priority to B or C. Both situations are dangerous and require emergency planning. Some would argue that the lethality of MIC outweighs the presence of good safety and prevention proce- dures; others would argue that the frequency of highway interchange accidents is reason enough to place greater emphasis on planning to deal with an ammonia incident. Each planning team must make such judgments on priorities in light of local circumstances. Before initiating plan development, the planning team should complete an assessment of available response resources, including capabilities provided through mutual aid agree- ments. Guidance for conducting such an assessment is presented in the following sec- tion. 3.4 Capability Assessment This section contains sample questions to help the planning team evaluate preparedness, prevention, and response resources and capabilities. The section is divided into three parts. The first part covers questions that the planning team can ask a technical repre- sentative from a facility that may need an emergency plan. The second part includes questions related to transportation. The third part addresses questions to a variety of response and government agencies, and is designed to help identify all resources within a community. This information will provide direct input into the development of the hazardous materials emergency plan and will assist the planning team in evaluating what additional emergency response resources may be needed by the community. 3.4.1 Facility Resources What is the status of the safety plan (also referred to as an emergency or contingency plan) for the facility? Is the safety plan consistent- with any community emergency plan? D Is there a list of potentially toxic chemicals available? What are their physical and chemical characteristics, potential for causing adverse health effects, con- Page 28 ------- trols, interactions with other chemicals? Has the facility complied with the com- munity right-to-know provisions of Title III of SARA? D Has a hazards analysis been prepared for the facility? If so, has it been up- dated? Has a copy been provided to the local emergency planning committee? D What steps have been taken to reduce identified risks? D How does the company reward good safety records? D Have operation or storage procedures been modified to reduce the probability of a release and minimize potential effects? D What release prevention or mitigation systems, equipment, or procedures are in place? D What possibilities are there for safer substitutes for any acutely toxic chemicals used or stored at the facility? D What possibilities exist for reducing the volume of the hazardous materials in use or stored at the facility? D What additional safeguards are available to prevent accidental releases? D What studies have been conducted by the facility to determine the feasibility of each of the following approaches for each relevant production process or opera- tion: (a) input change, (b) product reformulation, (c) production process change, and (d) operational improvements? D Are on-site emergency response equipment (e.g., fire fighting equipment, per- sonal protective equipment, communications equipment) and trained personnel available to provide on-site initial response efforts? D What equipment (e.g., self-contained breathing apparatus, chemical suits, un- manned fire monitors, foam deployment systems, radios, beepers) is available? Is equipment available for loan or use by the community on a reimbursable ba- sis? (Note: Respirators should not be lent to any person not properly trained in their use.) D Is there emergency medical care on site? D Are the local hospitals prepared to accept and provide care to patients who have been exposed to chemicals? D Who is the emergency contact for the site (person's name, position, and 24-hour telephone number) and what is the chain of command during an emer- gency? D Are employee evacuation plans in effect and are the employees trained to use them in the event of an emergency? D What kinds of notification systems connect the facility and the local community emergency services (e.g., direct alarm, direct telephone hook-up, computer hook-up) to address emergencies on site? D What is the mechanism to alert employees and the surrounding community in the event of a release at the facility? Page 29 ------- D Is there a standard operating procedure for the personal protection of commu- nity members at the time of an emergency? D Does the community know about the meaning of various alarms or warning sys- tems? Are tests conducted? D How do facility personnel coordinate with the community government and local emergency and medical services during emergencies? Is overlap avoided? D What mutual aid agreements are in place for obtaining emergency response assistance from other industry members? With whom? D Are there any contacts or other pre-arrangements in place with specialists for cleanup and removal of releases, or is this handled in-house? How much time is required for the cleanup specialists to respond? Q What will determine concentrations of released chemicals existing at the site? (Are there toxic gas detectors, explosimeters, or other detection devices posi- tioned around the facility? Where are they located?) D Are wind direction indicators positioned within the facility perimeter to determine in what direction a released chemical will travel? Where are they located? D Is there capability for modeling vapor cloud dispersion? D Are auxiliary power systems available to perform emergency system functions in case of power outages at the facility? D How often is the safety plan tested and updated? When was it last tested and updaied? D Does the company participate in CHEMNET or the CAER program? D Does the company have the capability and plans for responding to off-site emer- gencies? Is this limited to the company's products? What is the safety training plan for management and employees? D Are employees trained in the use of emergency response equipment, personal protective equipment, and emergency procedures detailed in the plant safety plan? How often is training updated? D Are simulated emergencies conducted for training purposes? How often? How are these simulations evaluated and by whom? When was this last done? Are the local community emergency response and medical service organizations invited to participate? D Are employees given training in methods for coordinating with local community emergency response and medical services during emergencies? How often? D Is management given appropriate training? How frequently? Is there an emergency response equipment and systems inspection plan? D Is there a method for identifying emergency response equipment problems? Describe it. D Is there testing of on-site alarms, warning signals, and emergency response equipment? How often is this equipment tested and replaced? Page 30 ------- 3.4.2 Transporter Resources What cargo information and response organization do ship, train, and truck operators provide at a release? D Do transport shipping papers identify hazardous materials, their physical and chemical characteristics, control techniques, and interactions with other chemi- cals? D Do transports have proper placards? D Are there standard operating procedures (SOPs) established for release situ- ations? Have these procedures been updated to reflect current cargo charac- teristics? D Who is the emergency contact for transport operators? Is there a 24-hour emergency contact system in place? What is the transport operation's chain of command in responding to a release? What equipment and cleanup capabilities can transport operations make available? D What emergency response equipment is carried by each transporter (e.g., pro- tective clothing, breathing apparatus, chemical extinguishers)? D Do transports have first-aid equipment (e.g., dressings for chemical burns, and water to rinse off toxic chemicals)? D By what means do operators communicate with emergency response authori- ties? D Do transport operations have their own emergency response units? D What arrangements have been established with cleanup specialists for removal of a release? What is the safety training plan for operators? D Are operators trained in release SOPs and to use emergency response equip- ment? How often is training updated? D How often are release drills conducted? Who evaluates these drills and do the evaluations become a part of an employee's file? D Are safe driving practices addressed in operator training? What monetary or promotional incentives encourage safety in transport operation? Is there a transport and emergency response equipment inspection plan? D What inspections are conducted? What leak detection and equipment readiness tests are done? What is the schedule for inspections and tests? D Are problems identified in inspections corrected? How are maintenance sched- ules established? Page 31 ------- 3.4.3. Community Resources What local agencies make up the community's existing response preparedness network? Some examples include: D Fire department; D Police/sheriff/highway patrol; D Emergency medical/paramedic service associated with local hospitals or fire and police departments; P Emergency management or civil defense agency; D Public health agency; D Environmental agency; D Public works and/or transportation departments; n Red Cross; and D Other local community resources such as public housing, schools, public utili- ties, communications. What is the capacity and level of expertise of the community's emergency medical facili- ties, equipment, and personnel? Does the community have arrangements or mutual aid agreements for assistance with other jurisdictions or organizations (e.g., other communities, counties, or States; indus- try; military installations; Federal facilities; response organizations)? In the absence of mutual aid agreements, has the community taken liability into consideration? What is the current status of community planning and coordination for hazardous materi- als emergency preparedness? Have potential overlaps in planning been avoided? D Is there a community planning and coordination body (e.g., task force, advisory board, interagency committee)? If so, what is the defined structure and author- ity of the body? D Has the community performed any assessments of existing prevention and re- sponse capabilities within its own emergency response network? D Does the community maintain an up-to-date technical reference library of re- sponse procedures for hazardous materials? D Have there been any training seminars, simulations, or mock incidents per- formed by the community in conjunction with local industry or other organiza- tions? If so, how frequently are they conducted? When was this last done? Do they typically have simulated casualties? Who are the specific community points of contact and what are their responsibilities in an emergency? D List the agencies involved, the area of responsibility (e.g., emergency re- sponse, evacuation, emergency shelter, medical/health care, food distribution, control access to accident site, public/media liaison, liaison with Federal and State responders, locating and manning the command center and/or emer- Page 32 ------- gency operating center), the name of the contact, position, 24-hour telephone number, and the chain of command. D Is there any specific chemical or toxicological expertise available in the commu- nity, either in industry, colleges and universities, poison control centers, or on a consultant basis? What kinds of equipment and materials are available at the local level to respond to emer- gencies? How can the equipment, materials, and personnel be made available to trained users at the scene of an incident? Does the community have specialized emergency response teams to respond to hazard- ous materials releases? D Have the local emergency services (fire, police, medical) had any hazardous materials training, and if so, do they have and use any specialized equipment? D Are local hospitals able to decontaminate and treat numerous exposure victims quickly and effectively? D Are there specialized industry response teams (e.g., CHLOREP, AAR/BOE), State/Federal response teams, or contractor response teams available within or close to the community? What is the average time for them to arrive on the scene? D Has the community sought any resources from industry to help respond to emergencies? Is the community emergency transportation network defined? D Does the community have specific evacuation routes designated? What are these evacuation routes? Is the general public aware of these routes? D Are there specific access routes designated for emergency response and serv- ices personnel to reach facilities or incident sites? (In a real incident, wind direc- tion might make certain routes unsafe.) Does the community have other procedures for protecting citizens during emergencies (e.g., asking them to remain indoors, close windows, turn off air-conditioners, tune into local emergency radio broadcasts)? Is there a mechanism that enables responders to exchange information or ideas during an emergency with other entities, either internal or external to the existing organizational structure? Does the community have a communications link with an Emergency Broadcast System (EBS) station? Is there a designated emergency communications network in the commu- nity to alert the public, update the public, and provide communications between the com- mand center and/or emergency operating center, the incident site, and off-scene sup- port? Is there a back-up system? D What does the communications network involve (e.g., special radio frequency, network channel, siren, dedicated phone lines, computer hook-up)? D . Is there an up-to-date list, with telephone numbers, of radio and television sta- tions (including cable companies) that broadcast in the area? Page 33 ------- D Is there an up-to-date source list with a contact, position, and telephone num- ber for technical information assistance)? This can be Federal (e.g., NRC, USCG CHRIS/HAGS, ATSDR, OHMTADS), State, industry associations (e.g., CHEMTREC, CHLOREP, AAR/BOE, PSTN), and local industry groups (e.g., local AlChE, ASME, ASSE chapters). Is there a source list with a contact, position, and telephone number for community re- sources available? D Does the list of resources include: wreck clearing, transport, cleanup, disposal, health, analytical sampling laboratories, and detoxifying agents? Have there been any fixed facility or transportation incidents involving hazardous materials in the community? What response efforts were taken? What were the results? Have these results been evaluated? 3.5 Writing an Emergency Plan When the team has reviewed existing plans, completed a hazards identification and analysis, and assessed its prepared- ness, prevention, and response capabili- ties, it can take steps to make serious in- cidents less likely. Improved warning sys- tems, increased hazardous materials training of industry and local response personnel, and other efforts at the local level, can all make a community better prepared to live safely with hazardous ma- terials. The team should also begin to write an emergency plan if one does not already exist, or revise existing plans to include hazardous materials. Chapter 4 describes two approaches to developing or revising an emergency plan. Chapter 5 describes elements related to hazardous materials incidents that should be in- cluded in whichever type of plan the com- munity chooses to write. Page 34 ------- 4. Developing the Plan 4.1 Introduction Most communities have some type of writ- ten plan for emergencies. These plans range from a comprehensive multi-hazard approach as described in FEMA's CPG 1-8 (Guide for Development of State and Local Emergency Operations Plans) to a single telephone roster for call-up pur- poses, or an action checklist. Obviously the more complete and thorough a plan is, the better prepared the community should be to deal with any emergency that occurs. As noted in Chapter 1, the " Emergency Planning and Community Right-to-Know Act of 1986" requires local emergency planning committees to develop local plans for emergency responses in the event of a release of an extremely hazard- ous substance. Those communities re- ceiving FEMA funds are required to incor- porate hazardous materials planning into their multi-hazard emergency operations plan (EOP). Other communities are en- couraged to prepare a multi-hazard EOP in accord with CPG 1 -8 since it is the most comprehensive approach to emergency planning. Not every community, however, may be ready for or capable of such a comprehensive approach. Because each community must plan in light of its own situation and resources, a less exhaustive approach may be the only practical, real- istic way of having some type of near- term plan. Each community must choose the level of planning that is appropriate for it, based upon the types of hazard found in the community. This chapter discusses two basic ap- proaches to writing a plan: (1) develop- ment or revision of a hazardous materials appendix (or appendices to functional an- nexes) to a multi-hazard EOP following the approach described in FEMA's CPG 1-8, and (2) development or revision of a plan covering only hazardous materials. Each approach is discussed in more detail below. 4.2 Hazardous Materials Appendix to Multi-Hazard EOP The first responders (e.g., police, fire, emergency medical team) at the scene of an incident are generally the same what- ever the hazard. Moreover, many emer- gency functions (e.g., direction and con- trol, communications, and evacuation) vary only slightly from hazard to hazard. Procedures to be followed for warning the public of a hazardous materials incident, for example, are not that different from procedures followed in warning the public about other incidents such as a flash flood. It is possible, therefore, to avoid a great deal of unnecessary redundancy and confusion by planning for all hazards at the same time. A multi-hazard EOP avoids developing separate structures, re- sources, and plans to deal with each type of hazard. Addressing the general as- pects of all hazards first and then looking at each potential hazard individually to see if any unique aspects are involved result in Page 35 ------- efficiencies and economies in the long run. Multi-hazard EOPs also help ensure that plans and systems are reasonably compatible if a large-scale hazardous ma- terials incident requires a simultaneous, coordinated response by more than one community or more than one level of gov- ernment. A community that does not have a multi- hazard plan is urged to consider seriously the advantages of this integrated ap- proach to planning. In doing so, the com- munity may want to seek State govern- ment advice and support. CPG 1-8 describes a sample format, con- tent, and process for State and local EOPs. It recommends that a multi-hazard EOP include three components a basic plan, functional annexes, and hazard-spe- cific appendices. It encourages devel- opment of a basic plan that includes ge- neric functional annexes applicable to any emergency situation, with unique aspects of a particular hazard being addressed in hazard-specific appendices. It stresses improving the capabilities for simultane- ous, coordinated response by a number of emergency organizations at various lev- els of government. Local communities that receive FEMA funds must incorporate hazardous materials planning into their multi-hazard EOP. In most of these com- munities, there are paid staff to do emer- gency operations planning as well as re- lated emergency management tasks. CPG 1-8 provides flexible guidance, rec- ognizing that substantial variation in plan- ning may exist from community to com- munity. A community may develop a separate hazardous material appendix to each functional annex where there is a need to reflect considerations unique to hazardous materials not adequately cov- ered in the functional annex. On the other hand, a community may develop a single hazardous materials appendix to the EOP, incorporating all functional annex consid- erations related to hazardous materials in one document. The sample plan format used in CPG 1-8 is a good one, but it is not the only satisfactory one. It is likely that no one format is the best for all com- munities of all sizes in all parts of the country. Planners should, therefore, use good judgment and common sense in ap- plying CPG 1-8 principles to meet their needs. The community has latitude in for- matting the plan but should closely follow the basic content described in CPG 1-8. CPG 1-8 should be used in preparing the basic plan and functional annexes. This guide should be used as a supplement to CPG 1 -8 to incorporate hazardous materi- als considerations into a multi-hazard EOP. Communities that want to develop Standard Operating Procedures (SOP) manuals could begin with information in- cluded in the functional annexes of a multi-hazard EOP. A community that is incorporating hazard- ous materials into a multi-hazard EOP should turn to Chapter 5 of this guide for a discussion of those elements which need to be taken into account in hazardous ma- terials planning. 4.3 Single-Hazard Emergency Plan If a community does not have the re- sources, time, or capability readily avail- able to undertake multi-hazard planning, it may wish to produce a single-hazard plan addressing hazardous materials. Exhibit 4 identifies sections of an emer- gency plan for hazardous materials inci- dents. The sample outline is not a model. It is not meant to constrain any community. Indeed, each community should seek to develop a plan that is best suited to its own circumstances, taking advantage of the sample outline where appropriate. Page 36 ------- The type of plan envisioned in the sample outline would affect all governmental and private organizations involved in emer- gency response operations in a particular community. Its basic purpose would be to provide the necessary data and documen- tation to anticipate and coordinate the many persons and organizations that would be involved in emergency response actions. As such, the plan envisioned in this sample outline is intended neither to be a "hip-pocket" emergency response manual, nor to serve as a detailed Stan- dard Operating Procedures (SOP) manual for each of the many agencies and organi- zations involved in emergency response actions, although it could certainly be used as a starting point for such manuals. Agencies that want to develop an SOP manual could begin with the information contained under the appropriate function in Plan Section C of this sample outline. If it is highly probable that an organization will be involved in a hazardous materials incident response, then a more highly de- tailed SOP should be developed. Exhibit 4 SAMPLE OUTLINE OF A HAZARDOUS MATERIALS EMERGENCY PLAN (NOTE: Depending upon local circumstances, communities will develop some sections of the plan more extensively than other sections. See page 39 for how the sample outline relates to SARA Title III requirements.) A. Introduction 1. Incident Information Summary 2. Promulgation Document 3. Legal Authority and Responsibility for Responding 4. Table of Contents 5. Abbreviations and Definitions 6. Assumptions/Planning Factors 7. Concept of Operations a. Governing Principles b. Organizational Roles and Responsibilities c. Relationship to Other Plans 8. Instructions on Plan Use a. Purpose b. Plan Distribution 9. Record of Amendments B. Emergency Assistance Telephone Roster C. Response Functions* 1. Initial Notification of Response Agencies 2. Direction and Control *These "Response Functions" are equivalent to the "functional annexes" of a multi-haz- ard emergency operations plan described in CPG 1-8. (continued on next page) Page 37 ------- Exhibit 4 (Continued) SAMPLE OUTLINE OF A HAZARDOUS MATERIALS EMERGENCY PLAN 3. Communications (among Responders) 4. Warning Systems and Emergency Public Notification 5. Public Information/Community Relations 6. Resource Management 7. Health and Medical Services 8. Response Personnel Safety 9. Personal Protection of Citizens a. Indoor Protection b. Evacuation Procedures c. Other Public Protection Strategies 10. Fire and Rescue 11. Law Enforcement 12. Ongoing Incident Assessment 13. Human Services 14. Public Works 15. Others D. Containment and Cleanup 1. Techniques for Spill Containment and Cleanup 2. Resources for Cleanup and Disposal E. Documentation and Investigative Follow-up F. Procedures for Testing and Updating Plan 1. Testing the Plan 2. Updating the Plan G. Hazards Analysis (Summary) H. References 1. Laboratory, Consultant, and Other Technical Support Resources 2. Technical Library Page 38 ------- 5. Hazardous Materials Planning Elements 5.1 Introduction This chapter presents and discusses a comprehensive list of planning elements related to hazardous materials incidents. Communities that are developing a haz- ardous materials appendix/plan need to review these elements thoroughly. Com- munities that are revising an existing ap- pendix/plan need to evaluate their present appendix/plan and identify what elements need to be added, deleted, or amended in order to deal with the special problems associated with the accidental spill or re- lease of hazardous materials. Title III of SARA requires each emer- gency plan to include at least each of the following. The appropriate section of the plan as indicated in Exhibit 4 is shown in parentheses after each re- quired Title III plan element. (1) Identification of facilities subject to the Title III requirements that are within the emergency planning dis- trict; identification of routes likely to be used for the transportation of substances on the list of extremely hazardous substances; and identifi- cation of additional facilities contrib- uting or subjected to additional risk due to their proximity to facilities, such as hospitals or natural gas fa- cilities. (Exhibit 4, Sections A.6 and G) (2) Methods and procedures to be fol- lowed by facility owners and opera- tors and local emergency and medi- cal personnel to respond to any re- leases of such substances. (Exhibit 4, Section C) (3) Designation of a community emer- gency coordinator and facility emer- gency coordinators, who shall make determinations necessary to imple- ment the plan. (Exhibit 4, Section A.7b) (4) Procedures providing reliable, ef- fective, and timely notification by the facility emergency coordinators and the community emergency co- ordinator to persons designated in the emergency plan, and to the public, that a release has occurred. (Exhibit 4, Sections C.1 and C.4) (5) Methods for determining the occur- rence of a release, and the area or population likely to be affected by such release. (Exhibit 4, Sections A.6 and G) (6) A description of emergency equip- ment and facilities in the community and at each facility in the commu- nity subject to Title III requirements, and an identification of the persons responsible for such equipment and facilities. (Exhibit 4, Section C.6) (7) Evacuation plans, including provi- sions for a precautionary evacu- ation and alternative traffic routes. (Exhibit 4, Section C.9b) (8) Training programs, including sched- ules for training of local emergency response and medical personnel. (Exhibit 4, Sections C.6 and F.1) Page 39 ------- (9) Methods and schedules for exercis- pear in the sample outline for a hazardous ing the emergency plan. (Exhibit 4, materials emergency plan in Chapter 4. Section F.1) Community planners might choose, how- ever, to order these planning elements The various planning elements are dis- differently in a multi-hazard plan following cussed here in the same order as they ap- the model of CPG 1-8. 5.2 Discussion of Planning Elements The remainder of this chapter describes in detail what sorts of information could be in- cluded in each element of the emergency plan. These issues need to be addressed in the planning process. In some cases, they will be adequately covered in SOPs and will not need to be included in the emergency plan. Planning Element A: Introduction Planning Element A.1: Incident Information Summary D Develop a format for recording essential information about the incident: Date and time Name of person receiving call Name and telephone number of on-scene contact Location Nearby populations Nature (e.g., leak, explosion, spill, fire, derailment) Time of release Possible health effects/medical emergency information Number of dead or injured; where dead/injured are taken Name of material(s) released; if known o Manifest/shipping invoice/billing label o Shipper/manufacturer identification o Container type (e.g., truck, rail car, pipeline, drum) o Railcar/truck 4-digit identification numbers o Placard/label information Characteristics of material (e.g., color, smell, physical effects), only if readily detectable Page 40 ------- 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. Page 41 ------- 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. Page 42 ------- Planning Element A.6: Assumptions/Planning Factors D 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, environmentally 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. Page 43 ------- Planning Element A.7b: Organizational Roles and Responsibilities D Municipal government Chief elected official Emergency management director Community emergency coordinator (Title III of SARA) Communications personnel Fire service Law enforcement Public health agency Environmental agency Public works D County government D Officials of fixed facilities and/or transportation companies Facility emergency coordinators (Title III of SARA) 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 Transportation organization Public safety organization D Federal government EPA FEMA DOT HHS/ATSDR USCG DOL/OSHA Page 44 ------- 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 pro-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. Page 45 ------- 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 NCP, 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 ------- Planning Element A.9: Record of Amendments D 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: Page 47 ------- Telephone Roster 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 Response Personnel Incident Commander Agency Coordinators Response Team Members Bordering Political Regions Municipalities Counties States 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 Media Television Newspaper Radio of SARA) Page 48 ------- Federal Emergency Management Agency 24 hours U.S. Department of Agriculture Occupational Safety and Health Administration Agency for Toxic Substances and Disease Registry 24 hours National Response Center 24 hours in Washington, DC area or U.S. Army, Navy, Air Force Bomb Disposal and/or Explosive Ordnance Team, U.S. Army Nuclear Regulatory Commission 24 hours U.S. Department of Energy Radiological Assistance 24 hours U.S. Department of the Treasury Bureau of Alcohol, Tobacco, and Firearms Other Emergency Assistance CHEMTREC 24 hours CHEMNET 24 hours CHLOREP 24 hours NACA Pesticide Safety Team 24 hours Association of American Railroads/ Bureau of Explosives 24 hours Poison Control Center Cleanup Contractor 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. Page 49 ------- Function 1: Initial Notification of Response Agencies D 24-hour emergency response hotline telephone numbers Local number to notify area public officials and response personnel Number to notify State authorities National Response Center (800-424-8802; 202-426-2675 or 202-267-2675 in Washington, DC area) D 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. The plan should indicate how volunteer and off-duty 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. Page 50 ------- 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. Page 51 ------- 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. 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 Page 52 ------- 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 \r\cldent 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- Page 53 ------- 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 D 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 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 Page 54 ------- 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 Page 55 ------- 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 Comment: The plan should clearly indicate what protective action should be taken in especially hazardous situations. Evacuation is sometimes, 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: Page 56 ------- 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 D 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 Page 57 ------- 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 D Relocation D Water supply protection 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.) Page 58 ------- 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. 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 Page 59 ------- 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 D 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. Planning Element D: Containment and Cleanup Planning Element D.1: Techniques for Spill Containment and Cleanup D Containment and mitigation actions D Cleanup methods D Restoration of the surrounding environment Comment: Local responders will typically emphasize the containment and stabilization of an incident; State regulatory agencies can focus on cleanup details. Federal Page 60 ------- 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 Page 61 ------- 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); 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. 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. Page 62 ------- 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; Page 63 ------- (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 D 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 make 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. Following are examples of information that must regularly be checked for accuracy: (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) D Identification of hazards D Analysis of vulnerability 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 Page 64 ------- 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 Page 65 ------- 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 any maps (e.g., of facili- ties, transportation routes) that will aid in the response to an accidental spill or release. 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, and be able to use avail- able hazardous materials data bases, including electronic data bases avail- able from commercial and government sources. 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. Page 66 ------- 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: Page 67 ------- 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. ^ 6. 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. Page 68 ------- 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. D 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. D Check all telephone numbers, persons named with particular responsibilities, and equipment Page 69 ------- 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- 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. D 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 D Attend any plan critique meet- ings and issue changes as may be required. D 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 capability 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 ------- 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. CMA 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. n 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- Page 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 this refresher training in conjunction with 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 ------- APPENDIX A IMPLEMENTING TITLE III: EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW: SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 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 III 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 III information can be used by local emergency planning committees. Exhibit 8 identifies various lists of chemicals mentioned in Title III 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- tions are interrelated in a way that unifies the emergency planning and community right-to-know provisions of Title III. (See Exhibit 6.) 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 III 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: Emergency Planning 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-1 ------- 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 on site and off site; procedures, 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 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 ------- 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 ------- 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 III planning re- quirements. Sections 311-12 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 ------- 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 MSOS. 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 ------- 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 must 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: Toxic Chemical Release Reporting 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 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, prdcessed, 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 in 1988 must report by July Page A-6 ------- 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 ------- 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. measures have been taken protect the confidentiality; to 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 The information is not required to be disclosed to the public under any other Federal or State law; 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. 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 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 ------- 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 ------- 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)) EPA publishes proposed formats for emergency inventory forms and reporting requirements in Federal Register (§ 311-12) 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)) 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 ------- 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 or List (§311) ------- EXHIBIT 7 INFORMATION FROM FACILITIES PROVIDED BY TITLE III IN SUPPORT OF LEPC PLAN DEVELOPMENT Information Generated by Title III Compliance Authority How LEPC Can Use the Information 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. 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. Hazardous Chemicals considered physical or health hazards under OSHA's Hazard Communication Standard (This is a performance standard, there is no specific list of chemicals.) Section 304: Emergency Notification Section 311: Material Safety Data Sheets Section 312: Emergency and Hazardous Chemical Inventory Identifies facilities subject to emergency notification requirements MSDS or list of MSDS chemicals provided by facilities to SERC, LEPC, and local fire department Covered facilities provide site-specific information on the quantity and location of chemicals to SERC, LEPC, and local fire departments to inform the community and assist in plan preparation. Toxic Chemicals identified as chemicals of concern by States of New Jersey and Maryland (329 chemicals/chemical categories) Section 313: Toxic Chemical Release Reporting These chemicals are reported on an emissions inventory to inform government officials and the public about releases of toxic chemicals in the environment. ------- 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) 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 Integrated Emergency Management System Local Emergency Planning Committee Material Safety Data Sheet National Agricultural Chemicals Association National Contingency Plan 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 ------- APPENDIX B (Continued) LIST OF ACRONYMS AND RECOGNIZED ABBREVIATIONS OSC On-Scene Coordinator OSHA Occupational Safety and Health Administration (DOL) PSTN Pesticide Safety Team Network RCRA Resource Conservation and Recovery Act RQs Reportable Quantities RRT Regional Response Team RSPA Research and Special Programs Administration (DOT) SARA Superfund Amendments and Reauthorization Act of 1986 (PL 99-499) SCBA Self-Contained Breathing Apparatus SERC State Emergency Response Commission SPCC Spill Prevention Control and Countermeasures TSD Treatment, Storage, and Disposal Facilities USCG U.S. Coast Guard (DOT) USDA U.S. Department of Agriculture USGS U.S. Geological Survey USNRC U.S. Nuclear Regulatory Commission Page B-3 ------- 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 ------- APPENDIX C (Continued) GLOSSARY CHRIS/HACS 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 OSCs use HACS 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 HACS 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 jurisdictions 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. EMI 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 ------- 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 ------- APPENDIX C (Continued) GLOSSARY ICS Incident Command System, the combination of facilities, equipment, personnel, procedures, and communications 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. NFA The National Fire Academy is a component of FEMA's National Emergency Training Center located in Emmitsburg, 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. NRC National Response Center, a communications center for activities related to response actions, is located at Coast Guard headquar- ters in Washington, DC. The NRC receives and relays notices of discharges or releases to the appropriate OSC, 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. NRT National Response Team, consisting of representatives of 14 government agencies (DOD, DOI. DOT/RSPA, DOT/USCG, EPA, DOC, FEMA, DOS, USDA, DOJ, HHS, DDL, Nuclear Regulatory Commission, and DOE), is the principal organization for imple- menting the NCP. When the NRT is not 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 ------- APPENDIX C (Continued) GLOSSARY sponse organization, and to recommend revisions to the NCP. 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. NSF National Strike Force, made up of three Strike Teams. The USCG counterpart to the EPA ERTs. NUREG 0654/ Criteria for Preparation and Evaluation of Radiological Emergency FEMA-REP-1 Response Plans and Preparedness in Support of Nuclear Power Plants, prepared by NRG 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 ------- APPENDIX C (Continued) GLOSSARY RCRA RRT SARA Superfund Title III Resource Conservation and Recovery Act (of 1976) established a framework for the proper management and 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. 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 ------- APPENDIX D CRITERIA FOR ASSESSING STATE AND LOCAL PREPAREDNESS C.1 INTRODUCTION The criteria in this appendix, an adaptation of criteria developed by the Preparedness Committee of the NRT in August 1985, represent a basis for assessing a State or local hazardous materials emergency response preparedness program. These criteria reflect the basic elements judged to be important for a successful emergency preparedness program. The criteria are separated into six categories, all of which are closely interrelated. These categories are hazards analysis, authority, organizational structure, communications, re- sources, and emergency planning. These criteria may be used for assessing the emergency plan as well as the emergency preparedness program in general. It must be recognized, however, that few State or local governments will have the need and/or capability to address all these Issues and meet all these criteria to the fullest extent. Resource limitations and the results of the hazards analysis will strongly influence the necessary degree of planning and prepared- ness. Those governmental units that do not have adequate resources are encouraged to seek assistance and take advantage of all resources that are available. Other criteria exist that could be used for assessing a community's preparedness and emergency planning. These include FEMA's CPG 1-35 (Hazard Identification, Capability Assessment and Multi-Year Development Plan for Local Governments) and CPG 1-8A. Additionally, States may have issued criteria for assessing capability. C.2 THE CRITERIA C.2.1 Hazards Analysis "Hazards Analysis" includes the procedures for determining the susceptibility or vulner- ability of a geographical area to a hazardous materials release, for identifying potential sources of a hazardous materials release from fixed facilities that manufacture, process, or otherwise use, store, or dispose of materials that are generally considered hazardous in an unprotected environment. This also includes an analysis of the potential or probable hazard of transporting hazardous materials through a particular area. A hazards analysis is generally considered to consist of identification of potential hazards, determination of the vulnerability of an area as a result of the existing hazards, and an assessment of the risk of a hazardous materials release or spill. The following criteria may assist in assessing a hazards analysis: D Has a hazards analysis been completed for the area? If one exists, when was it last updated? D Does the hazards analysis include the location, quantity, and types of hazardous materials that are manufactured, processed, used, disposed, or stored within the appropriate area? Page D-l ------- 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? a Have historical data on spill incidents been collected and evaluated? Q 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? 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 and what comprises that assistance or support? D Have the agency(ies) with authority to order evacuation 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 ------- locality to locality and that emergency planning for the State and local level may involve the preparation of multiple situation plans or development of a single comprehensive plan, the 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 ------- D Has one organization been given the command and control responsibility for 'these three phases of emergency response? 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? D Has a simulation exercise been conducted within the last 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 NCR? D Have trained and equipped incident commanders been identified? D Has the authority for site decisions been vested in the incident commanders? Q Have the funding sources for a response been identified? D How quickly can the response system be activated? 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. Coordination: D Have procedures been established for coordination of 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: D 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? Information Dissemination: 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: D 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: Q 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 ------- 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 take, 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 "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: D 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: 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? D 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? D Do mutual aid agreements exist to facilitate interagency support between organi- zations? Page D-6 ------- 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? a 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., explosivity meters, oxygen meters) analytical equipment or facilities available for sample analyses Page D-7 ------- fire-fighting equipment/other equipment and material (bulldozers, boats, helicopters, vacuum trucks, tank trucks, chemical retardants, foam) 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? D 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)? D Is there a mechanism to ensure that the lists are kept up-to-date? 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? 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? Fac///f/es: D Have facilities capable of performing rapid chemical analyses been identified? 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? D Have facilities and procedures been identified for housing persons requiring evacuation or temporary relocation as a result of an incident? D Have facilities been identified that are suitable for command centers? Page D-8 ------- 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.) D 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? D 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 ------- D Has a system been identified in the plan to carry out public information/commu- nity relations activities? 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? 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 ------- 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. 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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. Sittig, Marshall. Handbook of Toxic and Hazardous Chemicals and Carcinogens. Noyes, 1985. Smith, Al J. Managing Hazardous Substances Accidents. 1981. Page E-2 ------- 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 ------- 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. Sf. 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. 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. State Participation In the Superfund Remedial Pro- gram. Washington, DC: 1984. 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. EnvironrtSlfittil'^^ttion Agency. Standard Operating Safety Guides. Washing- ton, DC: 11 E-4 ------- 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) D "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 CM A. 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 ------- 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 30S 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 ------- Department of Commerce Department of State NOAA Superfund Program Coordinator Office of Oceans and Polar Affairs 11400 Rockville Pike Room 5801 Rockville, 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 ------- 2. REGIONAL OFFICES EPA, FEMA, HHS, ATSDR, OSHA Regional Offices U.S. COAST GUARD DISTRICTS Pacific Area ; COMPACAREA/ Atlantic Area COMPLANTAREA / 14th DUtrlct / n. 0 tt Quvd ldqu«rt«r« D.C. Page F-3 ------- REGIONAL OFFICES Department of Energy Regional Coordinating Offices for Radiological Assistance and Geographical Areas of Responsibility Alatk* 101 United States Nuclear Regulatory Commission Page F-4 ------- 2. REGIONAL OFFICES (Note: A. EPA Regional Offices Direct all requests to the "EPA Regional Preparedness Coordinator" (RPC) 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 ------- S. FEMA Regional Offices (Note: 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 ------- 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 ------- 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.) 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 Health 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 ------- 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 ------- 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 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 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) 8th District (Alabama, Florida, Georgia, Louisiana, Mississippi, New Mexico, Texas) 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 9th District (Indiana, Illinois, Michigan, Minnesota, Ohio, Pennsylvania, New York, Wisconsin 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 Commander (mep) 1240 East 9th Street Cleveland, OH 44199 (216) 522-3918 11th District (Arizona, California, Nevada, Utah) Commander (mep) Union Bank Building 400 Oceangate Long Beach, CA 90822 (213) 590-2301 Page F-10 ------- 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 ------- 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) 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 Operations 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 ------- 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 ------- /. 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) 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 Region 5 (Alaska, Arizona, California, Hawaii, Nevada, Oregon, Pacific Trust Territories, Washington) 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 USNRC Suite 210 1450 Maria Lane Walnut Creek, CA 94596 (415)943-3700 Page F-14 . 4U-S. Q.P.O. 1987-716-002160587 ------- |