- LA
Criteria for Review of
= Hazardous Materials =
   Emergency Plans
                      May 1988


            National  Response Team
                     of the National Oil and Hazardous
                        Substances Contingency Plan
               G-WER/12, 21OO 2nd Street SW, Washington, D.C. 2O593
                                       May 1988

  United States
  Coast Guard

 Department of

 Department of

 Department of

 Department of

 Department of

 Department of

 Department of

 Department of
   Health and
 Human Services


 Department of

 Department of
     This document transmits the National Response Team's recommended
criteria for reviewing emergency plans submitted to Regional Response
Teams (RRTs) under the provisions of Section 303(g) of the Emergency
Planning and Community Right to Know Act of 1986 ( SARA Title III).
The criteria for Review of Hazardous Materials Emergency Plans are to
serve as a supplement to the National Response Team's Hazardous Materials
Emergency Planning Guide (NRT-1) published in March 1987. In addition
to their use by the RRTs, the criteria also can be useful to State
Emergency Response Commissions (SERCs) and local Emergency Planning
Committees (LEPCs) in the development and review of plans.

      The National Response Team suggests the following for RRT reviews:
(1) Local plans should be submitted to the RRT throucpi the appropriate
State Emergency Response Commissions  (SERC) after the SERCs have completed
their own review; (2) Regional Response Team plan review should focus
primarily on plans prepared for designated priority areas within each
State, i.e. those areas where there are concentrations of hazardous
substances manufacturing, storage, or transportation facilities that
pose substantial hazards to the public health and safety, and should
ensure consistency between those local plans and the relevant Federal
plans; and (3) Regional Response Teams should use the review and comment
process as a form of technical assistance to SERCs and LEPCs. The reviews
do not constitute formal approval or disapproval.

      For further information concerning Regional Response Team reviews,
please contact:
Boston, MA (I)

New York, NY (II)
and Caribbean
Chicago,  IL (V)

Dallas, TX (VI)
Philadelphia,  PA (III)  Kansas City,  KS (VII)
215-597-9800           913-236-3888
San Francisco, CA  (IX)
and the Pacific Basin Region

Seattle, WA (X)

Anchorage,  AK
Atlanta, GA
           James L.
           U.S. Envi
Denver, CO (VIII)
              ital Protection Agency

               se Team
                           tain Robert L/
                        UJS.  Coast Guard
                        Vice Chairman
                        National Response Team
           Report Oil anXChemical Spills Toll Free (8OO)424-88O2


                        TABLE OF CONTENTS






     Incident Information Summary  	    6
     Promulgation Document 	    6
     Legal Authority and Responsibility for Response ....    7
     Table of Contents	    7
     Abbreviations and Definitions 	    7
     Planning Factors	    8
     Concept of Operations	   10
     Instructions for Plan Use .	   12
     Emergency Notification Procedures 	 ....   12
     Initial Notification of Response Agencies 	   14
     Direction and Control 	   15
     Communication Among Responders  	   16
     Warning Systems and Emergency Public Notification  ...   17
     Public Information and Community Relations   	   18
     Resource Management	   19
     Health and Medical	   20
     Response Personnel Safety 	  .....   21
     Personal Protection of Citizens/Indoor Protection  ...   22
     Personal Protective Measures/Evacuation Procedures   .  .   23
     Fire and Rescue .	   25
     Law Enforcement	   26
     On-Going Incident Assessment	  .   26
     Human Services	   27
     Public Works  	   27
     Techniques for Spill Containment and Cleanup   	   28
     Documentation and Investigative Follow-up 	   29
     Procudures for Testing and Updating the Plan	   29
     Training	   30



This document contains a set of criteria which may be used by the
Regional Response Teams (RRTs)  in the review of local plans under
the provisions of  Section  303(g)  of  the Superfund Amendments and
Reauthorization Act  of 1986 (SARA).   These criteria  also may be
used by local emergency planning committees (LEPCs) for preparing
plans  as  required under  Section 303(a)  and  by  state  emergency
response  commissions  (SERCs)  for  reviewing  plans  as  required
under Section  303(e)  of the Act.  This  review guide  is intended
as  a  companion  document  to the  Hazardous Materials  Emergency
Planning Guide (NRT-1), and can  be viewed as  a supplement to the
planning  process  as  implemented by  local  emergency  planning

Section  303(a)  of  the  Superfund Amendments  and Reauthorization
Act of  1986  requires each local  emergency planning committee to
prepare  comprehensive  hazardous  substances  emergency  response
plans by  October,  1988.  The  local  emergency planning committee
is required to review the plan once a year, or more frequently as
changed  circumstances  in  the  community  or at  any  facility may

Section  303(b)  requires each  local  emergency planning committee
to  evaluate   the   need  for  resources  necessary  to  develop,
implement,  and  exercise  the   emergency plan,   and  to  make
recommendations with  respect to  additional resources that may be
required and the means  for providing these  additional resources.

Section  303(c)   specifically   states   that  "Each  emergency
management plan shall include  (but is not  limited to) each of the

      (1)   Identification  of   facilities  subject  to  the
           requirements  of  this subtitle that are within the
           emergency  planning  district,   identification  of
           routes likely to be  used for the  transportation of
           substances  on  the  list  of  extremely  hazardous
           substances  referred  to  in  Section  302(a),  and
           identification    of   additional   facilities
           contributing  or  subjected to additional  risk due
           to  their proximity  to facilities  subject  to the
           requirements  of  this  subtitle,  such as hospitals
           or natural gas facilities.

     (2)  Methods  and  procedures  to  be followed by facility
         owners   and  operators  and  local  emergency  and
         medical  personnel to  respond to  any release  of
         such  substances.

     (3)  Designation  of a  community  emergency coordinator
         and   facility  emergency coordinators,  who  shall
         make  determinations  necessary  to implement  the

     (4)  Procedures  providing  reliable,  effective,  and
         timely   notification  by  the  facility  emergency
         coordinators   and  the   community  emergency
         coordinator   to  persons   designated   in  the
         emergency plan,  and to the public, that a release
         has   occurred  (consistent  with  the  emergency
         notification requirements of Section 304).

     (5)  Methods   for  determining   the  occurrence  of  a
         release, and the area  or  population  likely  to be
         affected by  such release.

     (6)  A  description  of   emergency  equipment  and
          facilities in the  community  and at each  facility
          in the  community subject  to  the  requirements of
         this   subtitle,  and  an  identification  of  the
         persons   responsible  for   such  equipment  and

     (7)  Evacuation  plans,  including  provisions   for  a
         precautionary  evacuation  and  alternative traffic

     (8)  Training programs,   including  schedules  for
          training of local  emergency response and medical

     (9)   Methods and  schedules for  exercising  the emergency

Under  Section  303(e)  of  the  Act,   state emergency  response
commissions are  required to review  and make recommendations on
each plan to ensure "coordination" with the plans of  other local
emergency planning districts.

Under Section 303(g) of the Act,  the Regional Response Teams  "may
review and comment upon an emergency plan  or other  issues related
to preparation, implementation,  or  exercise of such  a plan  upon
request of a local emergency planning committee."  This  review is
viewed by  the  National Response Team to  be a  form of  technical
assistance  to  the  local  emergency  planning committees  and the

state emergency response commissions, and is not to be considered
as an approval of these plans.

Finally,  under Section  303(f),  the National  Response  Team  is
required  to  issue  guidance  documents  for  the preparation  and
implementation of emergency plans.   In March,  1987 the National
Response Team published  and distributed the  first  such guidance
document  by  issuing NRT-1,  the  Hazardous Materials  Emergency
Planning Guide.  NRT-1 contains  extensive  discussion of both the
planning  process  and the  elements  or  contents required  for  an
effective  hazardous  materials  emergency   response plan.    The
following  plan  review  criteria  are   issued  as  supplemental
technical guidance to NRT-1.


The  review criteria  are based  on  the guidelines  for  plans  as
contained in Section 303(c) of the Act,  NRT-1, and CPG 1-8, Guide
for  Development  of  State  and Local Emergency  Operations Plans,
published  by  the Federal  Emergency Management Agency.   Section
303(c)  outlines the minimum  requirements  for local  emergency
response  plans.    The  criteria  which  address  these  minimum
requirements  are  introduced  throughout  the  document  by  the
phrase  "the  plan  shall."   The criteria based  upon NRT-1,  which
expand  upon  the  above  minimum  requirements,   include  all  the
elements  that  the  NRT  considers   essential   for  an  effective
hazardous  materials  emergency   response   plan.     While  local
emergency  planning  committee plans  are not required  to contain
all   these  elements,   the  NRT  believes   that   they  should.
Accordingly, the criteria based on the planning elements in NRT-1
(and  many of  the  elements  in  CPG 1-8)   are  introduced by  the
phrase  "the  plan  should."    In those cases  where  a plan  may  be
improved  by  including   other  considerations,  the  criteria  are
introduced by  the  phrase "the plan might."   In these  cases,  the
criteria are  not recommended either by Title III,  NRT-1,  or CPG

There  also  are criteria  included  in this document  that  are
considered to be  of  such  merit  that they are placed  under  the
category "the plan should", but cannot be specifically cited from
Title III, NRT-1,  or CPG  1-8.  These criteria will be included in
subsequent  revisions  to  NRT-1  ,and  are  highlighted  in  this
document with an asterisk  (*).

CPG  1-8  (used  as one of  the sources for these  criteria)  is used
by local governments  to  develop  emergency  operations plans which
are  required  by the  Comprehensive Cooperative Agreements between
the  Federal Emergency Management Agency and the states.   CPG  1-
8a,  Guide  for  the Review of  State and  Local Emergency Operations
Plans,  also was  used as a resource for developing these review
criteria.     The  planning  elements  in   CPG  1-8   have  been

incorporated into  NRT-1,  and most of the  review  criteria in CPG
l-8a are included  in the  attached RRT  Plan Review Document.   The
relevant sections of Title III, NRT-1,  and CPG 1-8 are indexed in
the review document for informational purposes.

The plan criteria  outlined below are structured to correspond to
the sequence  of plan elements suggested by  Chapters  4 through 6
of NRT-1 and Chapters 2 and 3 of CPG 1-8.


The NRT expects that the primary use of these criteria will be in
plan review by Regional Response Teams.  Through the use of these
criteria  and   the  development of  comments related thereto,  the
RRTs can  both conduct  organized  and systematic reviews of local
plans  and ensure  that plan  elements  of  particular  interest to
RRTs are  covered.    The RRTs should also  use the  criteria  as a
basis  for  ensuring coordination  between  federal  plans developed
under  the  National Contingency  Plan (e.g.,  Regional Contingency
Plans and OSC  Plans) and plans developed at the local level.

As  mentioned  above, the  local emergency  planning committees may
find  the criteria useful  in  the development  of plans  required
under  Section  303(c)  of  the  Act.   These criteria  are concise
statements of the  contents of plan elements covered in NRT-1 and
CPG 1-8, and  all of the plan elements required  in Section 303(c).
It  is essential,  however, that  the criteria  be used  by local
emergency planning committees  only in concert with the full range
of  available  guidance.

State  emergency response  commissions may  find the plan  criteria
useful in the coordination of  local  emergency planning committees
and in the review  of each local  plan. The  criteria  offer  a useful
guide  for  all of the   planning  elements  which  may  require
coordinated  and consistent treatment among  the  local emergency
planning  committees within a state.  They also provide the basis
for a more general review of  plans.


One of the major themes of NRT-1 is that the way  in which a  local
hazardous  materials emergency plan  is  developed is as  important
as  the  actual  contents   of  such  a plan.   Thus,  the  Regional
Response  Teams may   find it  useful  to  secure  the  following
information  pertaining to  the local emergency  planning  committee
under  review:

 1.   A list of the names and affiliations of the members of  the

A  description of the  activities and  accomplishments (with
completion  dates)  of  the  committee  in  compliance  with
Section 301, including:

     Appointment of a chairperson;

     Establishment of rules for committee operations;

     Development  of  methods  for  public  notification  of
     committee activities;

     Conduct of public meetings on the emergency plan;

     Receiving and responding to public comments; and

     Public  notice  of availability  of  emergency  response
     plan, Material  Safety  Data  Sheets, and inventory forms
     under Section 324;

     Dealing  with  public  requests  for  information under
     Sections 311, 312 and 313; and

     Securing  information  from  facilities  covered  by  the

A  description of the  major activities of  the committee in
completing  the  tasks for the hazard analysis and capability

A  summary  of  the   data  produced  by  these  tasks,  if  not
already described in the plan.

A  summary of the resources expended in developing the plan,
including local  funds, staff effort and technical expertise,
plus  a summary  of  resources  required for  maintaining and
revising  the  plan.

A  description  of any  findings  on  ways to  fund hazardous
materials emergency  planning within the district.



     The Plan should1 contain:

1.1  Detailed description of the  essen-
     tial information  that is to  be de-
     veloped  and recorded  by the local
     response system in an  actual inci-
     dent,  e.g.,  date,  time,  location,
     type of   release, and. material re-

     The Plan should contain:

2.1  A document signed by the chairperson
     of the LEPC,  promulgating  the plan
     for the district;

2.2  Documents signed by the chief execu-
     tives  of  all  local  jurisdictions
     within the district2; and
             A.2    2.3(a) (I)
     1  (a)  All  criteria with a Title III reference are required by section
  303(c) of the Act and are introduced by the phrase "The Plan shall."

        (b)  All  criteria with an NRT-1 reference  are not required by Title
III, but are regarded  as essential by the  NRT for an  effective hazardous
materials emergency response  plan.   They can be found in NRT-1,  Chapter 5,
"Planning Elements", and are introduced by the phrase "The Plan should."

        (c)  All  CPG 1-8 references include those  criteria that address re-
quirements for emergency operations plans prepared under the provisions of
the Comprehensive  Cooperative Agreements  with the  Federal Emergency Manage-
ment Agency.

     2 These  criteria are  considered to be  of  such merit  that they  are
included under  the heading  "the plan should", but cannot specifically be
cited  from Title  III,  NRT-1, or  CPG 1-8.    They are  designated in  the
documentation  section  by  an  asterisk   (*).   They  will be  included  in
subsequent revisions to NRT-1.

         CRITERIA FOR PLANS                             DOCOMENEATTON
                                                 TTITE III   NRT-1   CPG 1-8
2.3  Letters from affected facilities en-
     dorsing the plan.

     The Plan might contain:

2.4  letters  of  agreement  between  the
     affected facilities and local juris-
     dictions for  emergency response and
     notification responsibilities.

     The Plan should:

3.1  Describe,   reference,  or  include                    A. 3     2.3(h)
     legal  authorities  of  the jurisdic-
     tions whose emergency response roles
     are described in the plan, including
     authorities  of the  emergency plan-
     ning district and the local juris-
     dictions within the district; and

3.2  List all  other authorities the LEPC
     regards  as  essential  for response
     within the district, including state
     and federal authorities.

     The Plan should:

4.1  List all  elements of the plan, pro-                     A-4    2.3(a)(3)
     vide  tabs  for each  and  provide a
     cross-reference for all of the nine
     required  elements in  Section 303 of
     the Act.  Plans that are prepared in
     the  context of requirements  of CPG
     1-8  should contain an  index to the
     location  of both  NRT-1 and Section
     303 elements.

     The Plan should:


         CRITERIA FOR PLANS                             DOCUMENTATION
                                                 TTTIE III  NRT-1   CFG 1-8
5.1  Explain all abbreviations and define                    A.5    2.3(i)
     all essential terms  included in the
     plan text.


     Assumptions;    Assumptions are  the
     advance  judgments  concerning  what
     might happen  in the case  of an ac-
     cidental spill or release.

     The Plan should:

6.1  List  all of  the assumptions  about                    A.6    2.3(c)
     conditions that might develop in the
     district  in the event  of accidents
     from any  of the affected facilities
     or along any of the transportation

     Planning Factors

     The planning  factors consist of all
     the  local  conditions  that  make an
     emergency plan necessary.

     The Plan shall:

6.2  Identify and describe the facilities        303(c)(l)    A.6    2.3(c)
     in the district that possess extrem-
     ely  hazardous  substances  and  the
     transportation  routes  along  which
     such substances may  move within the

6.3  Identify  and  describe other facili-
     ties  that  may  contribute to  addi-
     tional risk by virtue of their prox-
     imity to the above mentioned facili-

6.4  Identify  and  describe  additional
     facilities  included in the plan that
     are subject to  additional risks due
     to  their  proximity  to  facilities

         CRITERIA FOR PLANS                             DOCUMENTATION
                                                 TITLE III   NRT-1   CPG 1-8
     with extremely hazardous substances;

6.5  Include methods for determining that        303(c) (5)    A.6     2.3(c)
     a  release  of  extremely  hazardous
     substances  has  occurred,  and  the
     area of population likely to be af-
     fected by such release.

     The Plan should:

6.6  Include the major findings from the                    A-6     2.3 (a) (4)
     hazard  analysis,   (date  of analysis
     should  be  provided)  which  should
     consist of:
                                                               ii        ii
6.6.1     Major  characteristics  of  af-
          fected  facilities/transporta-
          tion   routes  impacting  on the
          types  and   levels  of  hazards
          posed,   including  the  types,
          identities,   characteristics,
          and   quantities  of  hazardous
          materials related to  facilities
          and transportation  routes;
                                                               n        ii
6.6.2     Potential   release   situations
          with  possible consequences be-
          yond  the boundaries  of facili-
          ties,  or adjacent  to transpor-
          tation routes.  Use may be made
          of historical  data  on spills
          and any  data on  spills and any
          data  secured  from  facilities
          under Section 303(d)(3) of the
                                                                ii        11
6.6.3     Maps  showing locations of  fac-
          ilities,  transportation  rout-
          es,   and  special  features  of
          district,  including  vulnerable
                                                                n        n
6.7  Geographical  features of the dist-
     rict,   including  sensitive  environ-
     mental  areas,   land  use patterns,
     water  supplies,  and public transp-

         CRITERIA FOR PLANS                             DOCUMENTATION
                                                 TITLE III   NRT-1   CPG 1-8
6.8  Major  demographic  features  of  the                     A.6   2.3 (a) (4)
     district,  including those  features
     that  impact most  on emergency  re-
     sponse,  e.g.,  population  density,
     special populations, and particular-
     ly sensitive institutions;

6.9  The district's  climate and  weather                     "         "
     as they affect airborne distribution
     of chemicals; and

6.10 Critical time variables impacting on                     "         "
     emergencies,  e.g.,  time of  day  and
     month  of year  in which they  would
     be most likely occur.


     The Plan shall:

7.1  Designate a community emergency  co-        303 (c) (3)
     ordinator   and   facility  emergency
     coordinators, who  shall make deter-
     minations necessary to implement the

     The Plan should:

7.2  Identify, by title, the  individual                    A.7b   2.3(d)
     designated as the cxaranunity emergen-
     cy coordinator and each of the faci-
     lity emergency coordinators;

7.3  Explain  the  relationships  between
     these  coordinators,  their organiza-
     tions, and  the other  local  govern-
     mental  response authorities within
     the district, e.g., the county emer-
     gency management authority;

7.4  Describe  the  relationship  between                    A.7c
     this plan  and other  response  plans
     within the district  which  deal  in
     whole  or  in  part  with  hazardous
     materials  emergency response,  e.g.
     the county Emergency Operations Plan


         CRITERIA FOR PLANS                            DOCUMENTATION
                                                 TITLE III  NRT-1   CPG 1-8
     and plans developed by  fire depart-
     ments under  OSHA Regulation CFR 29
     Part 1910-120;

7.5  List  all  the  facility  emergency                    A-7c
     plans within the district that apply
     to hazardous materials emergency re-
     sponse, including all plans develop-
     ed under OSHA Regulation on Hazard-
     ous  Waste  Operations and Emergency
     Response (CFR 29 CFR Part 1910.120) ;

7.6  Describe the way in which the above
     plans are integrated with local res-
     ponse plans;

7.7  Describe the functions and responsi-                     A-7b   2.3(e)
     bilities of all the local response
     organizations within the district,
     including public and private sector
     as  well as volunteer and charitable

7.8  List mutual aid agreements or other                     A-3
     arrangements  for  sharing  data  and
     response resources;

7.9  Describe conditions under which the                     A. 7b
     local government will coordinate its
     response with other  districts  and
     the means or  sequence  of activities
     to be  followed by districts in in-
     teracting with other districts;

 7.10 Describe  the  relationship  between                    A.7c
     plans  of  the  district and  related
      state plans;

 7.11 Describe  the  relationship  between                    A-7b
      local  and  state  emergency response
      authorities; and

 7.12 Describe  the  relationships  between                    A'7b;
      emergency response plans and activi-                    A.7c
      ties  in the district  and response
      plans   and   activities  by  federal
      agencies,  including all  plans and


         CRITERIA FOR PLANS                             DOCUMENTATION
                                                 TITLE III   NRT-1   CPG 1-8

     responses  outlined in the National
     Contingency Plan.

     [Emphasis  should  be given  to  the
     allocation of responsibilities among
     federal emergency response agencies,
     including listing  the names  and the
     responsibilities of federal response
     agencies  and entities  such as  the
     KRT, describing the  means for their
     notification, the types of resources
     to  be sought from them,  the  means
     for  obtaining them,   the conditions
     under which assistance is to be pro-
     vided, and the methods  of coordina-    .
     tion during a response]


     The Plan should:

8.1  Contain a discussion of the purpose                    A.8a    2.3 (a) (5) (b)
     of the plan; and

8.2  Contain a list of  organizations and                    A.8b    2.3(a)(5)(c)
     persons receiving  the plan  or plan
     amendments  and the   date that  the
     plan was   transmitted as  well as a
     specific  identification  number  for
     each plan.


     The Plan should:

&M  Contain a section that   describes                    A.9     2.3(a)(6)
     methods for maintaining and revising
     the plan  and recording  all  changes
     in the plan,  including  a method for
     controlling distribution.


     The Plan shall:

         CRITERIA FOR PIANS                             KOJSIENIATION
                                                 TITLE III   NRT-1   CPG 1-8

10.1 Include  procedures   for  providing        303(c)(4)    C.4     3.3(c)
     reliable, effective,  and timely not-
     ification by  the facility emergency
     coordinators and the community.emer-
     gency coordinator  to persons desig-
     nated in the  emergency plan, and to
     the  public,  that  a  release  has

     The Plan should:

10.2 Include  procedures  for immediately                    C.I
     notifying  the  appropriate  24-hour
     hotline  first,  and  should  locate
     these  procedures   in  a  prominent
     place in the plan;

10.3 List  the 24-hour  emergency hotline
     number(s)  for  the  local  emergency
     response organization(s)  within the

10.4 Contain  an accurate  and up to-date                      B
     Emergency  Assistance Telephone Ros-
     ter that includes  numbers for the:

10.4.1    Technical  and response person-                      "

10.4.2    Community  emergency  coordina-                      *
          tor, and all  facility emergency

10.4.3    CHEMTREC;                                            B

10.4.4    National Response  Center;3

10.4.5    Other participating agencies;

10.4.6    Community  emergency  coordina-                      *
          tors  in  neighboring emergency
          planning districts;
     3  Spills  exceeding the CERCIA reportable quantities are required
to be reported  to the National Response Center.                     ,   

         CRITERIA FOR PLANS                             DC)OJMENTATION
                                                 TITLE III   NRT-1   CPG 1-8
10.4.7    Public and private sector sup-                     B
          port groups;  and the

10.4.8    Points of contact for all major
          carriers on transportation rou-
          tes within the district;

10.5 List all  local organizations  to  be
     notified of a release, and the order
     of  their   notification,   and  list
     names and telephone numbers of prim-
     ary and alternate points of contact;

10.6 List all  local  institutions  to  be
     notified of the occurrence of a re-
     lease and  the order  of their noti-
     fication,   and the  names  and tele-
     phone numbers of contacts;

10.7 List all  state organizations  to  be                     -*
     notified,   and  list  the  names  and
     telephone numbers of contacts; and

10.8 List all  federal  response organiza-                     *
     tions to be notified, and the names
     and telephones numbers of  the con-

     The plan should:

11.1 Describe methods or means to be used                     c-l
     by  facility  emergency coordinators
     (FECs) within the district to notify
     community   emergency  coordinators
     (CECs) of  any  potentially affected
     districts,   and  SERCs of  any poten-
     tially  affected   states,   and  any
     other persons to whom  the facility
     is to give notification of  any re-
     lease,  in  compliance with  Section
     304 of Title III;

11.2 Describe methods  by which the CECs
     and   local   response  organizations


         CRITERIA FOR PLANS                             IX)CUMENTATION
                                                 TITLE III   NRT-1   CPG 1-8
     will be notified  of releases  from
     transportation accidents,  following
     notification through  911 systems or
     specified alternative means;

11.3 Describe methods  by which  the  CEC,                    C.I
     or his designated agent, will ensure
     that contents  of  notification match
     the  requirements  of  Section  304,
     including the  regulations contained
     in 40 CFR Part 355 (Notification Re-
     quirements, Final Rule);

11.4 List  procedures  by  which  the  CEC                      "
     will assure that  both the immediate
     and  follow-on notifications  from
     facility operators are  made, within
     the time  frames specified  by Noti-
     fication  of Final Rule  in  40  CFR
     Part 355; and

11.5 Identify  the person  or  office  re-                      "
     sponsible  for  receiving the noti-
     fication for the community emergency
     coordinator  or  his/her  designated
     agent and list the telephone number;

     The Plan shall:

12.1 Include methods and procedures to be        303(c)(2)
     followed by  facility owners and op-
     erators and local emergency and med-
     ical  personnel to respond  to a re-
     lease  of  extremely hazardous  sub-

     The Plan should:

12.2 Identify the organization within the                     c-2    3.3(a)
     district  responsible  for providing
     direction and control to the overall
     emergency  response system described
     in the Concept of Operations;

         CRITERIA FOR PLANS                             DOOJMENIATION
                                                 TITLE III   NKT-1   CPG 1-8

12.3 Identify persons  or  offices  within                     C.2     3.3 (a)
     each response  organization who pro-
     vide direction and control to each
     of the organizations;

12.4 Identify persons  or offices provid-
     ing  direction  and  control  within
     each of the emergency response func-                       -

12.5 Describe persons  or offices respon-                      "
     sible  for  the performance of inci-
     dent command functions and the way
     in which the incident command system
     is  used   in  hazardous   substances

12.6 Describe  the  chain of command for                      "
     the total  response system, for each
     of the major response functions and
     for  the organization controlled by
     the incident commander; and

12.7 Identify   persons  responsible  for                      "
     the activation and operations of the
     emergency  operations  center, the on-
     scene  command post, and the methods
     by which  they will coordinate their

12.8' Last three levels of  incident sever-
     ity and associated response levels;

12.9 Identify   the conditions   for  each
     level;  and

12.10  Indicate the responsible organiz-
     ations at  each level.

      The Plan should:

 13.1 Describe all  the  methods  by which                    c-3    3.3(b)
      identified responders will  exchange
      information  and   communicate  with
      each other during  a response,   in-


         CRITERIA FOR PLANS                            DCX3JMENTATTON
                                                TITLE III   NRT-1    CPG 1-8
     eluding the ccmmunications  networks
     and common frequencies to be used;

     [At a minimum, these  methods should
     be described for each function.  Both
     communications among  local  response
     units  and between  these units  and
     facilities  where   incidents  occur
     should be described]

13.2 Describe the methods  by which emer-                    C.3
     gency responders can  receive infor-
     mation  ort  chemical   and   related
     response measures;  and

     [May include a description of compu-
     ter systems with on line data bases]

13.3 Describe primary and back-up systems                      *     3.3(b)
     for  all communication  channels and

     The Plan might:

13.4 Contain a diagram  or matrix showing                      *
     the  flows of information within the
     response  system.

     The Plan should:

14.1 Identify responsible officials with-                     c-4    3.3(c)
     in  the  district  and  describe  the
     methods  by which they  will notify
     the  public  of a release  from any
     facility or along any transportation
     route,  including sirens  or  other
     signals,  and  use of  the broadcast
     media  and  the Emergency Broadcast
     System.  This  should  include a des-
     cription of:

14.1.1   The sirens and other signals to
          be   employed,  their   meaning,
          their  methods of  coordination,


         CRITERIA FOR PLANS                            DOCUMENTATION
                                                TITLE III   NRT-1   CPG 1-8
          and  their  geographical   cov-

14.1.2    Other methods, such as door-to-                    C.4    3.3(c)
          door  alerting,  that may  be
          employed to  reach segments  of
          the population that may not be
          reached by sirens or other sig-
          nals; and

14.1.3    Time  frames  within which  not-                     "
          ification to  the public can be

14.2 Describe methods  for the  coordina-
     tion of emergency public  notifica-
     tion during a response; and
                                  .                            ii        ii
14.3 Describe   any  responsibilities  or
     activities of facilities  covered by
     the Act for emergency public notifi-
     cation during a response.


     The Plan should:

15.1 Describe the methods used by  local                    c-5    3.3(d)
     governments,  prior to  emergencies,
     for educating the  public  about pos-
     sible  emergencies  and  planned  pro-
     tective measures;

15.2 Describe the role and organizational
     position of the public information
     officer during emergencies;

15.3 Designate  a  spokesperson  and  des-
     cribe  the methods for keeping the
     public  informed during an emergency
     situation,  including  a list of all
     radio, TV, and press contacts; and

15.4 Describe  any related public  infor-                      *
     nation  activities  of affected faci-

         CRITERIA FOR PLANS                             DCXXIMENTATION
                                                 TITLE III   NKT-1   CPG 1-8
     lities, both prior to  an emergency
     and during an emergency.

     The Plan shall:

16.1 Include a description  of emergency        303(c) (6)
     equipment and facilities in the com-
     munity and  at each  facility  in the
     community  subject  to the  require-
     ments of this subtitle and an ident-
     ification of the persons responsible
     for such equipment and facilities.

     The Plan should:

16.2 List  personnel resources  available                     C.6    3.3(n)
     for emergency response by major cat-
     egories,    including  governmental,
     volunteer, and the private sector;

16.3 Describe the types, quantities, cap-                      "        "
     abilities and locations of emergency
     response equipment  available  to the
     local emergency response units,  in-
     cluding fire,  police and emergency
     medical response units.

     [Categories of  equipment should in-
     clude  transportation,   communica-
     tions,  monitoring   and  detection,
     containment,  decontamination,   re-
     moval, and cleanup]

16.4 List  the  emergency  response  equip-                      "        "
     ment  available  to each  of the  af-
     fected facilities and describe them
     in the same way as community  equip-
     ment is described;

16.5 Describe  the   emergency  operating                      *
     centers or  other facilities  avail-
     able to the local  community and the
     facility emergency coordinators  and
     other response coordinators, such as
     incident commanders;


         CRITERIA FOR PLANS                             DCIOJMENTATION
                                                 TITLE III   NRT-1   CPG 1-8
16.6 Describe  emergency response  equip-                     C'6     3*3t  '
     ment  and  facilities  available  to
     each affected facility  and the con-
     ditions under which they  are  to be
     used in support of local responders;
                                                               n         ii
16.7 Describe significant resource short-
     falls and mutual support agreements
     with other jurisdictions whereby the
     district  might  increase its capabi-
     lities in an emergency;

     [This  may  be  discussed  under the
     Concept of Operations]
                                                               n         "
16.8 Describe   procedures  for  securing
     assistance  from  federal  and  state
     agencies  and their emergency support

     [This  may  be  discussed  under the
     Concept of Operations]

16.9 Describe   emergency  response  capa-
     bilities  and the expertise  in the
     private  sector that might be  avail-
     able to   assist  local responders,
     facility  managers,  and transporta-
     tion companies  during emergencies.


     The Plan shall:

 17.1 Include methods and procedures to be         303(c) (2)
      followed by facility owners  and op-
     erators and local emergency and med-
      ical personnel  to respond to  a re-
      lease of extremely hazardous  sub-

 The Plan should:

 17.2 Describe the procedures for summon-                      c-7     3.3(h)
      ing  emergency  medical  and  health
      department personnel;


         CRITERIA FOR PLANS             .                DCX3MENIATION
                                                 TITLE III   NRT-1   CPG 1-8
17.3 Describe  the  procedures  for  the                     C.7     3.3(h)
     major  types  of  emergency  medical
     services, including  first aid,  tri- ,
     age, ambulance service, and emergen-
     cy  medical  care,  using  both  the                              ,
     resources available within the dist-
     rict and those that can  be secured
     in neighboring districts;

17.4 Describe  the procedures to  be fol-                      "        "
     lowed for decontamination of exposed

17.5 Describe  the procedures for provid-               .       "
     ing  sanitation,  food,  water  sup-
     plies, and  safe  re-entry of persons
     to the accident area;

17.6 Describe  procedures for  conducting                      *
     health  assessments  upon  which  to
     base protective action decisions;

17.7 Describe  the  level  and  types  of                     C.7
     emergency medical  capabilities  in
     the district to  deal  with exposure
     of  people  to  extremely  hazardous

17.8  Describe the provisions  for emer-                      "
     gency mental health care; and

17.9 Indicate  mutual  aid agreements with                      *
     other  communities to provide backup
     emergency medical and health depart-
     ment personnel, and equipment.


     The Plan  should:

18.1 Describe  initial and follow-up pro-                     C.8
     cedures   for entering  and  leaving
     incident  sites,  including personnel
     accountability personnel safety pre-
     cautions, and medical monitoring;

         CRITERIA FOR PLANS                             IXX3JMENTATICW
                                                 TITLE III   NRT-1   CPG 1-8
18.2 Describe  personnel   and  equipment                    C.8
     decontamination procedures; and

18.3 List sampling,  monitoring and  per-
     sonnel  protective equipment  appro-
     priate to various degrees of hazards
     based  on EPA  levels of protection
     (A, B, C, & D) .

     [Just prior to publication of NRT-1,
     the  Occupational Safety  and  Health
     Administration (OSHA) published pro-
     posed  rules  (29 CFR Part 1910.120)
     to provide more definitive require-
     ments to plan for emergency response
     personnel safety.  If the LEPC plans
     include a section on this function,
     the plan elements listed in the OSHA
     regulation should be used]

     The Plan  shall:

19.1 Describe  methods  in  place  in the        303 (c) (5)
     community and in each  of the  affect-
     ed  facilities  for  determining the
     areas  likely  to be affected  by a

     The Plan  should:

19.2 Include methods  to predict the spe-                     c'9a
     ed, direction,  and  concentration of
     plumes  resulting from airborne re-
     leases,   and methods   for modeling
     vapor  cloud dispersion as  well as
     methods  to monitor  the release and
     concentrations in real time;

      [19.1 and 19.2 may  be considered in
     the  hazard analysis,  included  in
     Section 6,  Planning Factors]
19.3 Identify  the  decision making pro-

         CRITERIA FOR PLANS                             DOCUMENTATION
                                                 TITLE III   NRT-1   CPG 1-8

     cess, including  the decision making
     authority for indoor protection;

19.4 Describe the roles and activities of                      *
     affected facilities  in the decision
     making  for indoor protection deci-
     sions,  including the  determination
     that indoor sheltering is no longer

19.5 Indicate the  conditions under which                     C.9a   3.3(g)
     indoor  protection would be  recom-
     mended,  including the  decision mak-
     ing criteria;

19.6 Describe the methods for indoor pro-                      *
     tection  that would be  recommended
     for  citizens, including provisions
     for  shutting off ventilation  sys-
     tems; and

19.7 Describe the  methods  for educating                     C.9a
     the public on indoor protective mea-

     [May be discussed in the section on
     public information]


     The Plan shall:

20.1 Describe evacuation plans, including        303(c)(7)     C.9b   3.3(e)
     those for  precautionary evacuations
     and alternative traffic routes;

     The Plan should:

20.2 Describe the  authority for ordering
     or recommending  evacuation,  includ-
     ing  the   personnel  authorized  to
     recommend evacuation;

20.3 Describe the  authority  and  respon-
     sibility   of  various   governmental
     agencies and supporting private sec-


         CRITERIA FOR MANS                            DOCUMENTATION
                                                 TUTE III   NRT-1    CPG 1-8
     tor organizations,  such as the  Red
     Cross,  and  the  chain  of  command
     among them;

20.4 Describe the role  of the  affected                     *
     facilities in the  evacuation  deci-

20.5 Describe methods to be vised in evac-                    C.9b
     uation,  including  methods  for  as-
     sisting  the  movement  of  mobility
     impaired persons and in the evacua-
     tion  of  schools,  hospitals, prisons
     and other facilities;

20.6 Describe the relationship  of  evac-                     *
     uation procedures  to  other protec-
     tive measures.

20.7 Describe  potential  conditions  re-                    C.9b
     quiring evacuation,  i.e.,  the types
     of  accidental  releases and  spills
     that may require evacuation;

20.8 Describe evacuation routes, includ-                     "     3.3(e)
     ing primary and alternative routes;

     [These  may  be  either  established
     routes for the community or special
     routes appropriate to  the location
     of facilities]

20.9 Describe evacuation zones and dist-                     "
     ances and the basis for their deter-

     [These should be related to the loc-
     ation of facilities and  transporta-
     tion  routes  and the potential path-
     ways  of exposure]

20.10 Describe procedures  for precaution-                     "
     ary  evacuations of special popula-

20.11  List the mass  care facilities for                     "     3.3(f)
     providing  food,  shelter and medical
     care  to relocated populations;


         CKTIERIA FOR FLANS                             DCKIMENEAITON
                                                 TTTIE III   NRT-1   CPG 1-8
     [This  may be discussed  under  the
     human services section]

20.12 Describe procedures  for  providing                    C.ll   3.3(i)
     security  for  the  evacuation,   for
     evacuees and of the evacuated areas;

     [May be covered under the law  en-
     forcement discussions]

20.13 Describe methods for managing  the                    C.9b   3.3(e)
     flow  of  traffic  along  evacuation
     routes  and for keeping the general
     public from entering threatened are-
     as, including maps with traffic and
     other control points; and

     [May be covered in the law enforce-
     ment section]

20.14 Describe the procedures  for manag-
ing  an  orderly return of  people  to  the
evacuated area;

     The Plan should:

21.1 List  the  major  tasks  to be  per-                    C.10   3.3(k)
     formed  by  firefighters  in  coping
     with  releases of  extremely hazard-
     ous substances;

21.2 Identify the public and private sec-                      "
     tor  fire  protection  organizations
     with  a response capability and re-
     sponsibility for hazardous materials
                                                               11         it
21.3 Describe  the  command structure  of                               .
     multi-agency,   multi-jurisdictional
     incident  management   systems  in                             .
     place,  and identify applicable mut-
     ual aid agreements and Good Samari-
     tan provisions in place;

         CRITERIA FOR PLANS                             DOCUMENTATION
                                                 TITLE III   NRT-1   CPG 1-8

21.4 List available support systems, e.g.                    C.10   3.3(k)
     protective  equipment and  emergency
     response guides,  DOT Emergency Res-
     ponse  Guidebook,   mutual  aid  agre-
     ements,  and  good Samaritan  provi-
     sions; and

     [May be covered under resource man-

21.5 List and  describe any HAZMAT  teams                     *
     in the district.

     [May  be  covered  in  Section  21.2


     The Plan should:

22.1 Describe  the  command structure  of                   . C.ll   3.3(i)
     multi-agency,  multi-jurisdictional
     incident  management  systems   in
     place, and  identify  applicable mut-
     ual aid agreements and Good Samari-
     tan provisions in place;

22.2 List  the   major  law  enforcement
     tasks related to  responding to  re-
     leases of extremely hazardous mater-
     ials, including those related to se-
     curity for the accident site and for
     evacuation activities; and

22.3 List the locations of control points                     *
     for the performance  of tasks,  with
     appropriate maps.


     The Plan should:

23.1 Describe methods   in place  in  the                    c12   3.3(p)
     community and/or each of the affect-
     ed  facilities for determining  the

         CRITERIA FOR PLANS                             IXX3MENTATIC*!
                                                 TITLE III   NRT-1   CPG 1-8
     areas  likely to be affected by an
     ongoing release.
23.2 Describe methods for determining the                    C.12    3.3(p)
     private and public property that may
     be  in the affected  areas and  the
     nature of  the impact of the release
     on this property?

23.3 Describe methods and capabilities of                      "
     both  local  response  organizations
     and  facilities  for monitoring  the
     size,  concentration,  and  migration
     of leaks,  spills,  and releases,  in-
     cluding  sampling  around the  site;

23.4 Describe provisions for environmen-                      "
     tal assessments, biological monitor-
     ing, and contamination surveys;


     The Plan should:

24.1 List  the  agencies responsible  for                    C.13    3.3(m)
     providing  emergency human services,
     e.g., food,  shelter,  clothing, con-
     tinuity of medical care,  and crisis
     counseling; and

24.2 Describe  the  major human  services                      "         "
     activities and the means  for their

The Plan should:

25.1 Describe  the chain  of command  for                     C.-14    3.3(j)
     the performance of public works ac-
     tions in an emergency; and

25.2 list  all  major  tasks to be  per-                      "         "
     formed by the public  works depart-

         CRITERIA FOR PLANS                            DOCUMENTATION
                                                TITLE III   NKT-1   CPG 1-8
     ment in a hazardous materials  inci-

     The Plan should:                           ,   .

26.1 Explain the  allocation of responsi-           ,"' .      . D4
     bilities among local authorities and
     affected  facilities  and responsible
     parties for these activities;

26.2 Describe  the major  containment and
     mitigation activities  for all major
     types of HAZMAT incidents;

26.3 Describe  cleanup and  disposal ser-
     vices to  be  provided by the respon-
     sible parties and/or the local com- -          -          ,

26.4 Describe major methods  for cleanup;                    ;

26.5 Describe methods to  restore the sur-  .
     rounding  environment, including nat-         ,
     ural  resource   areas,   to  pre-
     emergency conditions;

26.6 Describe  the  provisions for long                     D-2
     term site control;                                         ,

26.7 List the location  of approved dis-
     posal  sites;

26.8 List cleanup material  and equipment
     available within the district;

      [May  be  covered   in  the  resource
     management section]

 26.9 Describe the capabilities of cleanup
     personnel; and

 26.10   List  the  applicable  regulations
     governing   disposal  of   hazardous
     materials in the district.


         CRITERIA FOR PLANS                             DOCUMEOTATION
                                                 TITLE III   NRT-1   CPG 1-8

     The Plan should:

27.1 List  all  reports required  in  the                     E
     district and  all offices and  agen-
     cies that  are responsible for pre-
     paring them following a release;

27.2 Describe the  methods  of evaluating
     responses  and identify persons res-
     ponsible for evaluations; and

27.3 Describe provisions  for cost recov-

     The Plan shall:

28.1 Include  methods  and  schedules  for        303 (c) (9)     F.I
     exercising the emergency plan.    ,

     The Plan should:

28.2 Describe the nature of the exercises
     for  testing  the  adequacy  of  the

28.3 List  the  frequency  of such  exer-
     cises, by type;

28.4 Include an exercise schedule for the
     current year and for  future years;

28.5 Describe the  role of affected faci-
     lities  or transportation  companies
     in these exercises; and

28.6 Describe  the  procedures  by  which                     F-6
     performance will be evaluated in the
     exercise, revisions  will be made to

         CRITERIA FOR PLANS '                            DOCUMENTATION
                                                 TITLE III   NRT-1   CPG 1-8
     plans, and  deficiencies in response
     capabilities will be corrected.

     The Plan shall:

29.1 Include the training  programs,  in-        303(c) (8)    6.4.3
     eluding schedules,  for  training of
     local emergency response and medical

     The Plan should:                                   ,

29.2 Describe  training  requirements  for                       *
     IEPC  members  and  all  emergency
     planners within the district;

29.3 Describe  training  requirements  for                       *
     all  major  categories of hazardous
     materials  emergency  response  per-
     sonnel,  incliJding  the  types  of
     courses and the number of hours;

29.4 list and  describe the training pro-                  .     *
     grams to support these requirements,
     including   all   training   to   be
     provided by the community, state and
     federal  agencies,  and  the  private
     sector; and

29.5 Contain a schedule of training ac-                       *
     tivities  for  the  current year  and
     for the following three years.
                                    &U.S. GOVERNMENT PRINTING OFFICE: 1992 - 626-435/60700