FEMA-10/ July 1981
Federal Emergency
Management Agency
PLANNING GUIDE AND CHECKLIST
for
HAZARDOUS MATERIALS
CONTINGENCY PLANS
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PLANNING GUIDE AND CHECKLIST
FOR
HAZARDOUS MATERIALS
CONTINGENCY PLANS
CONTRACT NO. 68-03-2648
Project Officers
Federal Emergency Management Agency
Plans and Preparedness
Carl R. Siebentritt
U.S. Environmental Protection Agency
Municipal Environmental Research Laboratory-Cincinnati
Frank Freestone
Federal Emergency Management Agency
Washington, D.C. 20472
U.S. Environmental Protection Agency
Edison, New Jersey 08817
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ACKNOWLEDGMENT
This document was developed for the Federal Emergency Management
Agency and the U.S. Environmental protection Agency by Dr. Frank C.
Gunderloy, Jr., and Mr. Wayne L. Stone of Rockwell International,
Newbury Park, California 91320, under Contract No. 68-03-2648.
DISCLAIMER
This report has been reviewed by the Federal Emergency Management
Agency and the U.S. Environmental Protection Agency and approved
for publication. Approval does not signify that the contents
necessarily reflect the views and policies of these Agencies nor
does any mention of trade names or commercial products constitute
endorsement or recommendation for use.
ii
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FOREWORD
This Planning Guide is designed to assist State and local officials
develop a plan to respond to hazardous chemical spillsfrom the
smallest to the most complex. It is the product of the thinking,
suggestions, questions, and comments of over 300 people in State
and local government, Federal agencies, and trade, professional, labor
service, and environmental organizations.
I have reviewed the document and found it to be a very comprehensive
guide to hazardous materials emergency planning. It not only
identifies the positive steps to be taken in the actual planning
process but also points out the common pitfalls to be avoided.
I personally feel the heads of all emergency service organizations
will want to review this Guide and mutually develop a plan to respond to
the threat of hazardous material incidents conmon to their comamities.
Director
Federal Emergency Management Agency
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A WORD OR TWO OF EXPLANATION ...
This document is probably like no other you have ever read' before.
The style is informal, even casual at points, with teasers and question-
nairescomplete with slightly sarcastic answerssprinkled throughout. The
idea behind this is to keep the reader interested, rather than burdening him
with a more formal approach. Not that we don't like formal reports; they
have their place. But we want to reach as many readers as possible with this
planning guide, and we know some people just won't stay with it if there's too
much formality.
Those readers are supposed to be people in state or local government
agencies who need to plan for responding to hazardous chemical spills. We
hope they are, because we cover all kinds of plans, from the simplest to the
most complex, so this guide should be useful to a lot of those people. And
we hope you are one of them.
We based this guide on what works. To find out what that is, we got cur-
rent plans, comments, suggestions, and an occasional bit of flack from over
300 people in state and local government, federal agencies, and trade, pro-
fessional, labor, service, and environmental organizations. Then we had 50
more review the first draft, and some people use it to make plans. What
you're reading is the result.
We think this will work for you. If it doesn't, let us know why. Or
even if it does, but you have some ideas for improving on it, we'd like to
know that, too. Write to:
Federal Emergency Management Agency
1725 I Street, N. W.
Washington, D.C. 20472
This guide will be followed by a training course on contingency planning,
available through both the U.S. EPA and FEMA. Detailed announcements of the
availability of such a course should be appearing shortly.
IV
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HEY!: ... WHO NEEDS IT?
YOU DO:
WHAT GOOD IS IT?
WELL, LET ME TELL YOU...
MR. GOVERNOR
MR. MAYOR
MR. AGENCY DIRECTOR
This guide, put in the hands of the right people, will assure that proper
planning for hazardous materials emergencies has been carried out for the
region under your jurisdiction. It will even tell you how to select those
"right people," and what to expect from them.
MR. PLANNER
This guide gives you everything you need to get over the planning hur-
dle. Not just what ought to be in your plan, but how to go about the actual
planning process, the common pitfalls of planning, and what type of plan you
really ought to be working on.
MR. MAN WITH A PLAN -
This guide will provide you the basis for deciding if what you have is
really any good, and even if it is, how to make it better.
WHAT MORE COULD YOU ASK FOR?
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CONTENTS
Section
Foreword
A Word or Two of Explanation iv
Hey!! ... Who Needs It? v
1.0 Preliminaries 1-1
1.1 Purpose of this Guide 1-1
1.2 Some Notes on Semantics 1-2
1.3 How to Use this Guide 1-4
1.3.1 Decision Points 1-4
1.3.2 Parts of the Guide 1-5
1.3.2.1 Awareness 1-5
1.3.2.2 Planning Process 1-6
1.3.2.3 Plan Development and Content 1-6
1.3.2.4 Plan Appraisal and Continuing Planning 1-7
1.4 Your Government: A Note on Sources of Information .... 1-7
2.0 Awareness 2-1
2.1 Who Should be Planning? 2-2
2.2 Why Plan? 2-5
2.3 What are the Approaches to Planning? 2-7
2.4 What Kind of Plan? 2-11
2.5 Hazards Analysis 2-17
2.6 Disasters 2-18
2.7 Decision Point //I 2-19
2.7.1 Do I Need a Contingency Plan or Not? 2-19
2.7.2 I'd Like to Have a Plan, BUT 2-21
2.7.3 Am I Ready to Start Planning? 2-22
2.7.4 Yes, I Want a Plan Prepared 2-25
3.0 The Planning Process 3-1
3.1 The Planner(s): Who and How to Select Them 3-1
3.1.1 IndividualGroup CoordinatorCommittee Chairman. . 3-2
3.1.2 Planning Groups and Committees 3-3
3.1.3 Consultant 3-6
3.1.4 Prime Planning Problems The Individual(s) 3-7
3.1.5 Prime Planning Problems The Group/Committee .... 3-7
3.2 Duties and Responsibilities of Planners 3-8
3.2.1 Hazards Analysis 3-8
3.2.2 Review Prior Plans 3-11
3.2.3 Response Planning: Identifying Functions of
Emergency Response or Support Groups 3-12
VI
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CONTENTS (Continued)
Section Page
3.2.4 Coordination Planning: Identifying Comprehensive
Emergency Responsibilities 3-12
3.2.A.I Coordination With Industry 3-16
3.2.5 Identify Deficiencies 3-16
3.3 Existing Plans: Interfaces, Coordinating and Use .... 3-17
3.4 Writing and Scheduling 3-21
3.5 Problem Areas and Suggested Approaches 3-22
3.6 The Model Plan (It's Not Recommended) 3-24
3.7 Decision Point #2 3-25
3.7.1 How Do I Go About Preparing the Plan? 3-25
4.0 Plan Development and Content 4-1
4.1 Plan Type 4-1
4.2 Plan Content 4-2
4.3 Detailed Plan Sections 4-7
4.3.1 Emergency Response Notification (Front Page
Notification) 4-8
4.3.2 Record of Amendments or Changes 4-9
4.3.3 Letter of Promulgation 4-9
4.3.4 Foreword/Preface 4-9
4.3.5 Acknowledgment . . . . 4-10
4.3.6 Table of Contents 4-10
4.3.7 Introduction 4-10
4.3.8 Emergency Response Operations 4-10
4.3.9 Emergency Assistance Telephone Roster 4-17
4.3.10 Legal Authority and Responsibility 4-17
4.3.11 Response Organization Structure/Responsibilities . . . 4-20
4.3.12 Disaster Assistance and Coordination 4-21
4.3.13 Procedures for Changing or Updating Plan 4-21
4.3.14 Plan Distribution 4-22
4.3.15 Spill Cleanup Techniques 4-23
4.3.16 Cleanup/Disposal Resources 4-24
4.3.17 Laboratory and Consultant Resources 4-25
4.3.18 Technical Library 4-25
4.3.19 Hazards Analysis 4-27
4.3.20 Documentation of Spill Events 4-30
4.3.21 Hazardous Materials Information 4-30
4.3.21.1 CHEMTREC 4-31
4.3.22 Training Exercises 4-32
4.4 Decision Point #3 4-33
4.4.1 What Type of Plan Do I Want? 4-33
4.4.2 What Sections Will the Plan Contain? 4-34
4.4.3 What Will be Detailed in Each Section? 4-35
5.0 Plan Appraisal and Continuing Planning 5-1
5.1 Plan Review and Approval 5-1
5.2 Keeping a Plan up to Date 5-4
5.2.1 Computer Techniques: Word Processing 5-6
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CONTENTS (Continued)
Section Page
5-3 Continuing Planning 5-7
5.4 Decision Point #4 5-12
5.4.1 Is My Plan Any Good? 5-12
5.4.2 How Do I Correct and Improve the Plan? 5-13
Plan Checklist c~l
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1.0 PRELIMINARIES
1.1 PURPOSE OF THIS GUIDE
THIS GUIDE WILL HELP YOU PREPARE A PLAN TO RESPOND PROPERLY TO SPILLS OF
DANGEROUS SUBSTANCES. There are an increasingly large number of chemicals,
oils, radioactive materials, and other hazardous substances spilled as the
result of highway, rail, and waterway accidents, storage tank leakage, pipe-
line break, or other "unscheduled events." On occasion, these events reach
major (disaster) proportions: huge explosions (BLEVEs*) as tank cars of liquid
petroleum gas rupture, clouds of chlorine gas force evacuation of homes, and
miles of beach are mired in oil. While these occasions are rare, they do
occur; it's wise to know how to cope. Better safe than sorry.
While major spills are rare, spills in general are not, and in some areas
there are daily occurrences in which tanks, drums, bags, bottles, pails, box-
es, puddles, streams, piles, and clouds of materials of varying degrees of
hazard are encountered dispersed in a manner that no one ever intended. These
messes can be further complicated by such factors as terrain, population,loca-
tion, weather, and human elements.
THIS GUIDE WILL:
Allow you to decide whether you need a contingency (preparedness)
plan to deal with spills
Help you select the type of plan you want
Work out procedures for preparing a plan consistent with your
capabilities
Help you select what should be in your plan
Provide a method for rating your plan when finished
THIS GUIDE WILL NOT (REPEAT, "NOT");
Give you a "f ill-in-the-blanks " model plan
Provide all details of response techniques (it will show you where
they are, how to get them, and how to assure their proper use,
however)
* Boiling-Liquid Expanding-Vapor Explosion.
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Train personnel to respond to spills (it will make suggestions on
training, however)
YOUR FINISHED PLAN, BY ITSELF, DOES NOT
ASSURE YOU THAT YOU CAN COPE WITH SPILLS.
People cope with spills, using techniques and equipment that are suitable
for the job. Planning is only one step in the process; it defines what should
be done, but it does not assure that it will be done.
When your plan is finished, it can become functional only if there exists
a lead agency, a group, a section, or an individual whose job it is to apply
the plan and see to it that:
Personnel are available
Personnel are trained
Everyone knows their role
Equipment is available
Equipment is maintained
Coordination/mutual aid truly exists
New developments/equipment are added
New hazards are identified
Phone numbers, etc., are kept up to date
Exercises are conducted
USEFUL RESPONSE ACTUALLY TAKES PLACE!
If you are thinking of making a plan "so we can have it in our files in
case we need it," STOP NOW! You are wasting valuable time that you can
spend doing something else.
1.2 SOME NOTES ON SEMANTICS
In State, County, and Local Governments throughout this nation, there are
almost as many different names of agencies as there are political entities,
and the division of responsibilities among those agencies that have identical
names will vary from entity to entity. For simplicity, we are using the fol-
lowing throughout this guide:
Environmental Protection Agency that agency that has the assign-
ment of control of environmental conditions and/or protection of
the environment from pollution. It might be called, among others:
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Department of Environmental Resources
Department of Fish & Game
Department of Water Resources
Air Pollution Control District
AND MANY MORE.
(Note; The Federal Agency is specifically identified as the U.S. EPA.)
Civil Defense that group which has the responsibility for mini-
mizing the effects of attack or disaster upon the civilian popula-
tion. Activities may include pre-disaster readiness (mitigation,
preparedness), and activities during and after disaster (response,
recovery). It might be called:
Office of Emergency Services
Civil Preparedness Office
State Emergency Office
(Note: The Federal Agency is specifically identified as the DCPA
or FEMA (Defense Civil Preparedness Agency or Federal Emergency
Management Agency). The former is found in documents and refer-
ences prior to the 1979 reorganization in the Federal Government.
The responsibilities and capability of DCPA are now found in and
augmented by FEMA.)
Department of Transportation that agency or agencies that has
jurisdiction over problems on highways, railroads, and waterways.
It might be called:
Highway Commission
Railway Commission
Port Authority
Public Works
(Note: The Federal Agency is specifically identified as the U.S.
DOT.)
Finally, you need to understand that there are many terms used inter-
changeably with the one we prefer: Hazardous Materials. These are substances
which, if released in an uncontrolled manner (i.e., spilled), can be harmful
to people, animals, property, and/or the environment. Other terms used are:
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Hazmat
Hazardous Substances
Toxic Substances
Dangerous Substances
Special Materials
Hazardous Chemicals
Etc.
Sometimes, particular classes of hazardous materials are mentioned:
Etiological (disease-carrying) agents
Radiological (nuclear) materials
Corrosives
Flammables
Carcinogens
Poisons
Oil spills
Etc.
1.3 HOW TO USE THIS GUIDE
1.3.1 Decision Points
In order to allow the user of this guide to apply it in the most appro-
priate fashion for his particular planning requirement, a number of DECISION
POINTS have been included in the body of this guide. DECISION POINTS allow
the user to decide what parts of this guide he needs or wants to use, as well
as clarify and organize his own assignment, goals, and objectives within the
planning framework.
DECISION POINTS are found at the end of each of the next four major sec-
tions of this guide:
AWARENESS, p. 2-19
PLANNING PROCESS, p. 3-25
PLAN DEVELOPMENT & CONTENT, p.4-33
PLAN APPRAISAL, p. 5-12
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The following approach is recommended for getting the most benefit from
the DECISION POINTS.
IF THIS IS YOUR FIRST PLAN, OR IF YOU WANT TO DO A COMPLETELY NEW PLAN,
read the text that precedes DECISION POINTS first, then go through the deci-
sion process to test yourself on what you have learned and what you want to
do next.
IF YOU ARE ALREADY EXPERIENCED IN PLANNING, REVISING, OR ARE ASSESSING
AN EXISTING PLAN:
Go through the DECISION POINTS first, using them to locate those parts of
the text that you may want to use to refresh yourself or to establish criteria
for reworking your present plan.
1.3.2 Parts of the Guide
This guide is divided into five parts:
1.0 PRELIMINARIES (which you are reading now)
2.0 AWARENESS
3.0 THE PLANNING PROCESS
4.0 PLAN DEVELOPMENT/CONTENT
5.0 PLAN APPRAISAL & CONTINUING PLANNING
You may need all of them, or none of them, depending on who you are,
what organization you represent, and whether your situation calls for a con-
tingency plan or not. This guide will allow you to decide whether you should
be developing a plan or not, how to go about it, what to put in, and whether
it is really what you want when you're done with it.
1.3.2.1 Awareness, p. 2-1
This section is designed to help you answer first the question:
DO I NEED A CONTINGENCY PLAN OR NOT?
If you know the answer, for sure, you may want to skip this section and
go on to the next. If, however, there is some degree of uncertainty in your
answer (yes, but...), or if you are about to embark on your first contingency
plan, then you will want to read through this section just to assure yourself
of your orientation in your planning mission. Start at the beginning, and
make sure you know: WHO SHOULD BE PLANNING? (pp. 2-2 to 2-4), WHY PLAN?
(pp. 2-5 to 2-6).
If you are absolutely sure that you need a plan, and it's your job to
get it underway, then this section will help you answer a second question:
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AM I READY TO START PLANNING?
Again, if you're sure you're ready, go on to the next section. But if
you have to analyze your answer ("I think so..."), you may want to at least
review parts of the AWARENESS section as follows:
APPROACHES TO PLANNING (pp. 2-7 to 2-10)
WHAT KIND OF PLAN? (pp. 2-11 to 2-16)
HAZARDS ANALYSIS, DISASTERS (pp. 2-17 and 2-18)
1.3.2.2 Planning Process
This section is designed to answer the question:
HOW DO I GO ABOUT PREPARING THE PLAN?
The answer to this question again assumes that the. people involved are
new to the concept of the contingency plan, and that their usual duties in
their organizations are other than the preparation of contingency plans. On
the other hand, professional planners may well want to skip this section of
the guide, and apply their own planning techniques and approaches, based on
their own particular systems and prior successful efforts.
Between these extremes, there will be people with varying levels of
skill and experience in planning, and the general typical areas from which
they may select are as follows:
THE PLANNER(S): WHO, AND HOW TO SELECT THEM (pp. 3-1 to 3-8)
DUTIES AND RESPONSIBILITIES OF PLANNERS (pp. 3-8 to 3-17)
EXISTING PLANS: INTERFACES, COORDINATING AND USE (pp. 3-17 to 3-21)
WRITING AND SCHEDULING (pp. 3-21 to 3-22)
PROBLEM AREA'S AND SUGGESTED APPROACHES (pp. 3-22 to 3-24)
1.3.2.3 Plan Development and Content
This section of the guide is designed to answer a series of questions:
WHAT TYPE OF PLAN DO I WANT? (pp. 4-1 to 4-2) ''
This question will have been given a general answer earlier; the decision will
now be confirmed.
WHAT SECTIONS WILL THE PLAN CONTAIN? (pp. 4-2 to 4-7)
Contingency plans may be broken down into a series of plan sections. You will.
be able to outline a plan.based on recommended sections' along with: optional
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sections to fit your own particular needs and circumstances.
WHAT WILL BE DETAILED IN EACH SECTION? (pp. 4-7 to 4-33)
Within each section, a plan must present certain useful information, estab-
lish a mechanism for contacts with other people/plans, describe or assign an
action or response, or otherwise tell what should be done. Depending upon
whether the plan is prepared for local, regional, or state-level action,
whether it is playing an administrative or coordinative role, or whether it is
describing the response role of an action agency, the content of each section
will vary. Where appropriate, suggested cutoff levels are given, as follows:
MINIMUM PLAN CONTENT
MAJOR PLAN
COMPREHENSIVE PLAN
Criteria for using the cutoff levels are provided within the Checklist (p. C-l).
1.3.2.4 Plan Appraisal and Continuing Planning
After a plan is in hand and complete, the question to be asked is:
IS THE PLAN ANY GOOD? (pp. 5-1 to 5-4)
This can be asked of a plan that has just been written, or a plan that has
been around for years (i.e., "IS MY PRESENT PLAN SATISFACTORY?"). A checklist
is provided for this purpose, but a checklist is a very elementary diagnostic
tool only. The real answer to the first question invariably is:
HOW DO I UPDATE, CORRECT, OR IMPROVE THE PLAN? (pp. 5-4 to 5-9)
Planning should never stop. Each experience with a plan, real or simu-
lated, will generate items that should be reviewed, discussed, and perhaps
result in plan additions, amendments, or changes. Mechanisms are suggested
for critical review and continuing planning to keep plans useful and updated.
HOW ABOUT EXERCISES AND TRAINING? (pp. 5-9 to 5-12)
Unless you are frequently responding to actual spills, the only way to keep
response skills sharp and get the bugs out of a plan is through exercises and
training courses. Techniques for getting the most out of exercises are given,
and some top-notch training courses are listed.
The most frequent cause of mismanagement of incidents is insufficient
training. Don't get caught in the trap of having a plan, but not really know-
ing what to do with it.
1.4 YOUR GOVERNMENT: A NOTE ON SOURCES OF INFORMATION
As you progress in this guide, and later as you progress in your planning
project, you are going to need--information about your local government, county,
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state government, federal government, industry, volunteer organizations, vol-
unteer fire departments, and so on.
THE PLANNER'S BEST FRIEND IS HIS TELEPHONE BOOK.
A few minutes spent looking at and browsing through the "State of...", "County
of...", "City of...", and "U.S. Government" listings will quickly provide you
with places to begin your inquiries arid requests. Furthermore, the Federal
Government and most states maintain Information Centers or Assistance Centers
whose numbers are in bold-face type in your phone book. With these, tyou can
generally find the help you want, even if you aren't sure exactly whose jur-
isdiction it falls under.
START AT THE TOP, IF YOU HAVE TO.
If you're having trouble orienting yourself with respect to state or inter-
state problems, and don't know where to turn, you can go to the Federal Re-
gional level. No matter where you are in the United States, and its posses-
sions, you are in
One of 10 U.S. EPA Regions
One of 10 FEMA Regions
One of 12 U.S. Coast Guard (U.S. DOT) Districts.
There are people at this level of the Federal Government who are well
acquainted with the problems of spills and disasters, and they are eager to
inform you of their role, as well as being acquainted with the state and
'interstate agencies within their districts/regions so'that they can direct
you to the appropriate person for further information.
ASK!
Don't be afraid to use that telephone. The people you-need to talk to
are in agencies or branches/departments/divisions of agencies whose primary
mission is assistance, not regulation. Your contact with them is an oppor-
tunity for them to see that their job gets done. They want to help.
KEEP RECORDS OF YOUR TELEPHONE CALLS, AND THE INFORMATION THAT THEY PRO-
VIDE. Do this from the very first call you make. We suggest a simple format:
Name: " Agency/Or ganization:
Date:
Telephone No:
Contact Summary:
The summary should contain notes on what you asked for, what's to be sent to
you, and when to expect it, references of whom else to contact, and any other
pertinent information.
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2.0 AWARENESS
Before you can get down to the nuts and bolts of an assembled plan, you
need a set of wrenches the appropriate planning tools. And before those
tools are used, you either have to train yourself or you have to select the
proper mechanic (planner) to wield them. AND even before that you have
to make sure that the finished product is going to be something that you want,
and need, and really should have. AWARENESS is where this all starts, and
this section of the guide will allow you to decide whether you need a plan,
and whether you're ready to start work on it. This is essentially an orienta-
tion section, and arrives at the answers you need by quickly (not comprehen-
sively) exploring a number of areas:
Who should be planning?
Why plan?
Approaches to planning
What kind of plan?
Hazards analyses
Disaster planning
71
37M-798 0 82 - 2 ^ ->-
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2.1
SHOULD BE PLANNING?
PEOPLE
Directors
Agency Heads
Branch Heads
Section Leaders
City Managers
Supervisors
Chiefs
Fire
Police
Lieutenants
Sergeants
Councilpersons
Mayors
Coordinators
AND
Their delegated planners
and representatives:
Your boss?
Your co-worker?
. YOU?
People need plans. Individuals who
are in positions of response and
responsibility at any level in any
organization and who may become
involved in an environmental emer-
gency a spill or release of a
hazardous material should be pre-
pared to act in the most appropriate
fashion. Advance planning is the
first step, and the key to a rapid
response that may save lives, prop-
erty damage, and both public and
private funds. When it finally comes
down to it, people take action in
emergencies. Plans make the differ-
ence between rational action and
haphazard reactions.
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AGENCIES
Federal
State
County/Parish
Local
Municipal
Volunteer
Administration
Environmental Protection
Military/National Guard
Natural Resources
Fire Department
Police Department
Fish & Game
Highways/Transportation
Flood Control
Harbor Commission/
Port Authority
Public Health
Rescue Squad
Civil Defense
Conservation
Forestry
Water Resources
Public Safety
Public Works
Agencies are those identifiable
organizations within the govern-
ment structure regardless of
the government level that have
the legal responsibility, the
jurisdictional authority, the
charter, or in some manner have
been identified as having a role
of coordination and/or response
in an environmental crisis. That
agency needs to define its re-
sponse in a contingency plan.
Agencies are groups of people,
and the key to a good plan is
assuring that each person knows
his role and what to expect of
other people with whom he must
interact. This advance knowledge
requires a plan, and familiariza-
tion with that plan by everyone
who must act under it.
An agency may have been defined
as the.Lead Agency, that agency
which is in charge when responses
take place under a comprehensive
plan for a region or a political
subdivision.
YOUR AGENCY?
YOUR DEPARTMENT?
YOU?
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AREAS
States
Counties
Parishes
Townships
Towns
. Cities
Communities
Municipalities
Boroughs
Regions
Intrastate
Interstate
Districts
YOUR HOME TOWN?
Industrial Complexes
River Valleys
Coastal Zones
Population Centers
Rural Areas
Ports
Transportation Routes
Areas may be government entities,
with boundaries defined by law, or
they may be geographical, with
boundaries determined by natural
features. The authority to do
something in an area will generally
be a government function. However,
the area that needs something may
well cross several different poli-
tical borders.
The hazardous chemical spills re-
sult from industrialization. How-
ever, this does not exempt rural
areas from the potential for dis-
aster, since most spills are
transportation-related, and the
highway-rail-pipeline-waterway-air
network exposes the entire
country to some degree of risk.
Indeed, because they may be less
well-equipped than large cities,
small towns/rural areas need plan-
ning more than anyone else, since
they may have to go far afield to
marshall the forces for response.
YOUR BACK YARD?
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2.2 WHY PLAN?
HAZARDS
Oil
Radiological Material
Chemicals
Flammable Corrosive
Toxic Oxidizing
Explosive
Etiological Agent
Manufacturing
Use
Storage
Terminals
Transportation
Highway Air
Rail Barge
Pipeline Ship
Tanker
Disposal
Spill
Leak
Seepage
Contamination
Vapor Cloud
Fire/Smoke
Pollution (air/water)
Earthquake
Flood
Windstorm
Snow/Ice/Hail Storm
Hurricane/Tornado
Fire
Technological Disaster
Hazards exist, and it is up to per-
sons in positions of authority to
protect the health, lives, well-
being, and property of the general
populace. Hazardous spills can
range from a one-pint chemical con-
tainer ruptured on the highway to a
technological disaster such as a
BLEVE* during a railroad tank car
derailment or a major oil tanker
incident leaving hundreds of miles
of coastline mired under crude pet-
roleum. Small spills can be multi-
plied by the hundreds, and compli-
cated by being part of the cleanup
problem associated with a flood or
other natural disaster.
In today's society, the need for
planned responses is acute. Elec-
ted, appointed, and staff members
of our representative form of gov-
ernment represent the people, and
good planning on their part is in
the people's best interest. Self-
preservation may still be instinc-
tive, but pure reflexive responses
no longer apply to many complex
modern situations. A new form of
self-preservation, based on plan-
ning and learning, has to be
developed.
* Boiling Liquid - Expanding Vapor Explosion.
2-5
-------
THE LAW
Federal Law
Clean Water Act (Section
311 of 33 USC* 1251)
State Laws
County & Municipal
Codes
Local Ordinances
Directives
National Contingency
Plan (40CFR** 1510)
Disaster Relief Act
(Section 201 of
Public Law 93-288)
Legal requirements for planning may
indeed exist at all levels of govern-
ment , but never assume that some
higher authority is looking out for
your interests or has the power to
respond to your local problems. In
general, laws at all levels make the
spiller legally liable for cleanup,
but can you tell that to an injured
truck driver? Or use it to make an
oil slick go back to sea? Someone
has to take command, assure that
things get done, and if necessary,
make the spiller discharge his re-
sponsibilities (particularly his
financial ones) after the fact.
The closer you can get to the imme-
diate problem of a spill, the faster
it can be taken care of, and some-
times "nipped in the bud" before it
escalates into a major disaster.
Thus, Federal Law invites state and
local participation, and many state
laws mandate local planning and par-
ticipation. If nothing else, muni-
cipal authorities should know how
to activate higher level plans that
can help them.
* U.S. Code.
** Code of Federal Regulations.
2-6
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2.3 WHAT ARE THE APPROACHES TO PLANNING?
THE INDIVIDUAL
City Manager
Agency Head
Appointed Planner
Staff Planner
YOU?
When an individual is solely re-
sponsible for planning, the range
of plan output will be limited by
the individual planner's knowledge
of planning principles and compre-
hension of inter-agency coordinat-
ing activities. However, plans
that are relatively narrow in scope,
such as telephone rosters, action
guides/checklists, and resources
lists can easily be completed by a
qualified individual. More compre-
hensive planning will require the
labors of an extremely well-informed
governmental official or someone who
has been assigned the job full time
and can really work at it. Plans
made by individuals don't require
coordination meetings, and are gen-
erally self-consistent. On the
other hand, they may take longer to
produce, and things can get over-
looked.
2-7
-------
THE GROUP
Interagency Task Force The planning group or committee is
the traditional vehicle from which
Designated Planning Group comprehensive coordinating plans
and emergency response plans are
Planning Committee developed. The planning group re-
flects the expertise of a variety
Coordinating Council of sources, thus ensuring the pro-
duction of an accurate and complete
document, if the group functions
smoothly.
However, a series of meetings is a
"must," and a strong group leader
or committee chairman will have to
make sure that things get done, that
the final plan is self-consistent.
An editor (who can be the group
leader) will have to make sure that
grammar, style, and content of
everything fits together at the end.
2-8
-------
THE CONSULTANT
Environmental Consulting A consultant may be contracted to
Firm prepare all or part of a plan. The
use of a consultant is most advan-
Job Shopper tageous when specialized skills are
required, qualified planners cannot
Planning Expert be identified, or tough deadlines
must be met.
Limited-Term Employee
Consulting rates will undoubtedly
be higher than regular employee
salary rates, but if the consultant
is appropriately selected, the in-
vestment can be cost-effective.
Make sure you get a plan that's been
prepared for your specific situa-
tion, not someone else's plan with
a new label on it.
2-9
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STATE/FEDERAL ASSISTANCE
Planning Guidelines
Planning Funds
Model Plans
Legislative Incentives
Federal and State authorities do
not usually make plans for politi-
cal entities within their jurisdic-
tion, but they do provide planning
aids and incentives. These assist-
ances are realized in the form of
funding for plan preparation, the
issuing of regulatory incentives,
and the publication of planning
guidelines and model formats.
Find out what's available in your
area.
2-10
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2.4 WHAT KIND OF PLAN?
Telephone Lists
Alternate Phone Numbers
Night Numbers
24-Hour Numbers
Alternate Communications
Radio Networks:
Police
Fire
Amateur
CB
. Radio, TV Stations
Relays
Addresses
TELEPHONE ROSTERS
Telephone Rosters are the simplest
type of plans, and it is possible
that you may need only one number,
if you are in an area that is served
by a comprehensive state or federal
system. You may need a series of
numbers if the state and local mech-
anisms to cope with problems are in
place, and all you have to know is
who to call to take care of particu-
lar problems. Under disaster condi-
tions, telephones may be inoperative,
so even these simplest of plans
should have alternate communications
to back them up.
If you elect to go with this simp-
lest of plans, you also might want
to back it up with a Resource &
Equipment list, so you'll know what's
available, as well as who to call
(see p. 2-13).
The Telephone Roster approach is
analogous to having the doctor,
ambulance, fire, and police numbers
handy to your home phone.
KEEP IT UP TO DATE:
2-11
-------
ACTION GUIDES/CHECKLISTS
First on the Scene
Who to Call
Information to Provide
Basic Actions
Save Life/Property
Fire Extinguishment
Shut Off
Identify
Contain
Prevent Access
Action Guides and Checklists are
generally short (one/two-page)
sheets or cards, preferably of an
easily carried size (pocket-
billfold-glove compartment) for
use by people who are most likely
to be the first to run into a
spill. They are generally a sub-
sidiary of some more comprehensive
plan, and are designed to assure
that a few basic things always get
done. They should never be relied
on as the sole response. They
should serve only as reminders to
persons who have had more compre-
hensive training, or as a method
for activating a more comprehensive
response. However, they may be all
that local people need, IF (and only
if-) they are covered by an active
state or federal plan.
The Action Guide/Checklist is simi-
lar to those handy home booklets,
"What To Do 'Til The Doctor Comes."
KEEP IT UP TO DATE!
2-12
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RESOURCE/EQUIPMENT LISTS
Fire Response Equipment
and Units
Earth-Moving Equipment
Trucks, Sweepers
Sand/Gravel
Booms and Skimmers
Disposal Capabilities/
Sites
Civil Defense Supplies
Cleanup Contractors
Personnel
Police Units
Hospitals/Doctors/
Nurses
Technical Experts
Resource and Equipment Lists are of
several types. Those maintained by
action response people so they know
what they have available, within
their own organization (e.g, fire
departments, public works depart-
ments, transportation/roads, etc.).
These may be assembled into an over-
all community or other regional lists
by coordinating response personnel.
The industrial community can provide
a wide range of equipment, sometimes
on a volunteer, sometimes on a direct-
hire basis. There are also an in-
creasing number of cleanup contract-
ors whose business is responding to
spills. Even when a community is
covered by an active state or re-
gional plan, it should know its local
capabilities, so the information can
be made available to whomever takes
charge in a spill or disaster.
People are also resources. They can
provide pure brainwork (technical
experts from local chemical compan-
ies, university professors), or pure
dogwork (volunteers on a sandbag
detail). Know how to find them and
how to muster and stage them.
The resource/equipment list is like
a drug and medical equipment catalog,
and it presupposes skilled personnel
who know what to do with the
resources.
KEEP IT UP TO DATE:
2-13
-------
Contingency Plan
Notification/Action
Response Organization
Response Procedures
Field Techniques
Telephone Roster
Update/Audit
Exercises/Training
Containment/Disposal
Resources
Maps/Technical Library
Vulnerable Areas
Hazards Analysis
RESPONSE PLANS
A Response Plan tells how to handle
an emergency spill situation. Its
emphasis will derive from who pre-
pares and uses it. An action or
designated response agency such as
fire department, Environmental Pro-
tection Agency, or Department of
Transportation may include detailed
specific field techniques. A com-
munity plan may, on the other hand,
define the responsibilities and cap-
abilities of various community action
agencies, and how to activate them.
There will also be some elements of
the COORDINATION PLAN (see next
page) in any Response Plan that is
prepared at the state and municipal
/-"*
level. (Pure Response and Pure
Coordination plans are rare.) If a
plan contains at least one telephone
number that activates or connects to
a functional organization that can
take care of the problem, it may be a
RESPONSE PLAN, regardless of what
else it contains.
The Response Plan is like a doctor's
office manual or a hospital procedure
book. It gets down to the realities
of what people are actually going to
do to take care of the mess.
KEEP IT UP TO DATE:
2-14
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COORDINATION PLANS
Legal Backing
Administrative Procedure
Responsibilities
Coordination
Charts
Annexes
Agencies
Disaster
Classifications
A Coordination Plan is generally
aimed at carefully defining the re-
sponsibilities of various agencies,
groups, or individuals under various
emergency response conditions. State
disaster plans prepared by Civil De-
fense organizations are often pri-
marily coordination plans and many
of them cover hazardous materials
spills technological disasters
as part of a matrix of who does what
during different kinds of disasters.
As mentioned on the prior page,
there are generally some elements of
RESPONSE found in coordination plans.
Use the "telephone number" rule of
thumb to decide which is which.
Do not fall into the trap of assum-
ing that all agencies have accepted
and can discharge the responsibili-
ties outlined in a coordination plan.
Implementation can lag behind, de-
pending on budgets, personnel, and
timing.
The Coordination Plan is like a theo-
retical medical textbook: It contains
a lot of useful knowledge, but may
require some supplemental laboratory
workbook or training to put it into
actual practice.
KEEP IT UP TO DATE:
2-15
-------
Informal
"Let Joe Do It"
Second Level
Volunteer
Established
Memoranda
Manual
AD HOC PLANS
The Ad Hoc Plan is generally highly
functional, and grew to fill a need
to respond to a problem. Trying to
make an immediate conversion to a
formal plan may be difficult, or even
a mistake. People tend to become
highly proprietary about their areas
of work, particularly with increased
years on the job.
Although we may not like to admit it,
governments communicate and function
at a lot of different levels, and
Ad Hoc plans are generally based on
second-level, informal lines of con-
tact. If you have a functional AD
HOC plan, you might want to let it
alone, but you always run the risk
of losing the capability. If "Old
Joe," who has taken care of things
for years, retires, his knowledge
goes with him. And there are other
problems, like who has the legal
duty to respond, and if there are
liabilities and expenses, who pays?
Joe might be the guy you need to head
up a new planning group and response
team (with some appropriate recog-
nition for his efforts). If not,
maybe you can get him to begin to
document his work as a series of
memoranda or by writing a training
manual for others in the department.
Home remedies and midwifery still
flourish in some parts of the country.
If they can get the job done, fine.
However, there may be a better way.
KEEP IT UP TO DATE'.
2-16
-------
2.5 HAZARDS ANALYSIS
Rail Lines
Highways
Intersections
Chemical Production
Chemical Use
Paints/Solvents
Plastics
Cleaners/Caustics
Plating
Compressed Gas
Pipelines
Gasoline
Service Stations
Tanker Trucks
. River/Canal Traffic
Barge/Ship
Airport
Agriculture
Ammonia
Pesticides
Waste Disposal
. Oil
Wells
Storage
Refineries
Terminals
Vulnerable Areas
Environmentally Sensitive
Areas
Pollution Sources
PLANNING STARTS with knowing what
your problem is. The specific chem-
ical HAZARDS in your area are a
complex formation of the oil,
refined products, and chemicals that
are entering, made, used, and leaving
your community. Second, the routes
and locations are of great concern,
primarily with respect to endangering
homes and business centers. Then,
the probability of an incident a
spill needs to be determined.
Forget about lightning spills often
do strike in the same place, or at
least close to each other, in highly
industrialized areas with heavy truck
and rail traffic.
Finally, make sure you know where
your most vulnerable (water supplies/
intakes, for example) and what your
most sensitive areas are (public
schools and parks?). If you have
conducted a hazard/vulnerability
analysis, use it to begin planning.
If not, be sure it's the first thing
you do in getting your plan under way.
2-17
37t-798 0 82 - 3
-------
2.6 DISASTERS
Fire
Flood
Windstorm
Snow/Ice/Hail
Earthquakes
Avalanche
Volcano
Tidal Wave
Technological Event
Explosion
BLEVE
Oil Tanker
Chemical Dispersions
Civil Defense
Interfaces
Mutual Aid
State Disaster Plans
National Plan
U.S. EPA*
U.S. DOT** (Coast Guard)
FEMA***
Chemical spills reach DISASTER pro-
portions in two ways. First, they
may be of such magnitude (the tech-
nological event) that they constitute
disasters in themselves. Second,
they may be complicating factors in
a natural disaster. A flood, in its
wake, may leave hundreds and hundreds
of chemical containers corroding in
the mud, their labels obliterated.
The capabilities of local and munici-
pal authorities are invariably insuf-
ficient to cope with disasters in
themselves, but capabilities exist at
the state and federal levels to meet
these needs. Local plans need to be
able to establish interfaces with
other local plans (mutual aid) and
with all the higher level plans.
Communication routes, under all con-
ditions, need to be clearly defined.
* Environmental Protection Agency
** Department of Transportation
*** Federal Emergency Management Agency
2-18
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2.7 DECISION POINT NUMBER 1
2.7.1 Do I Need a Contingency Plan or Not?
a. YES, without qualification CH . Skip down to 2.7.3.
b. YES, because I don't have one [~| .
Are you sure?
Have you checked with
Local Fire Yes D No H]
Police Yes D No Q
Environmental Agency Yes Q No | |
(Use your
telephone! Dept. of Transportation Yes Q No H
See p. 1-8)
Civil Defense Yes £] No Q
You might be covered by a plan already.
c. YES, because I see hazard potential Lj .
Do you have?
Highway Yes H No Q
Railway Yes |) No Q
Waterway Yes Q No \ [
Pipeline Yes P] No Q
Industry Yes Q No H]
Agriculture Yes r] No [~|
Have you done a Hazard Analysis? Yes Q No !|
If not, make it Item #1 in your plan.
d. YES, because it's the lawLJ .
State? D County? D Local? Q Municipal? Q
Get a copy; and make sure you understand the exact legal
requirements. Then skip down to 2.7.2.
2-19
-------
e. YES, because I was directed by
Name
Title
Are you sure he's right?
Go back to 2.7.1, b. Maybe there's a plan already.
f. YES, because I've been named a member of/appointed to/asked to
attend a planning group Q .
You will probably be responsible for some particular plan
section. Skip to 2.7.3.
g. YES, but/because
Write in any other qualifications above the answer might appear
elsewhere in the brochure, and you should record your initial mis-
givings before going further.
************
h. NO, without qualificationO . You are finished with this guide.
Give it to your boss or circulate it to your co-workers.
i. NO, I have one already Q .
Is it any good?
Go to Decision Point 4, page 5-12.
j. NO, I'm covered by the __ plan.
(name)
Oh?
Have you
Seen it in action? Yes Q No Q
Called some of the phone numbers to see if they're
current? Yes No
2-20
-------
Determined its response time?
Minutes?
An hour?
Hours?
How many? (use your telephone)
Asked around? Yes Q] No Q
Is your answer still NO? If not, start over.
k. NO, I have nothing to be afraid of £] .
Not likely. Go back to 2.7.1, c and think about it.
1. NO, it's 's job, not mine.
Name
Agency
Check the lists on pp. 2-2 and 2-3 (Who Should Plan?).
You're not there? Yes Q] No Q
Input from you needed? Yes Q No j~]
Maybe just some advice? Yes [H No Q]
m. NO, but/because
Write in any other qualifications above, and go back and review pages
2-2 to 2-18 of this guide. You might change your mind. At least you've
recorded your present reason, and have it to refer to if things change
later on.
************
2.7.2 I'd Like to Have a Plan, BUT
(a) I don't know how to go about it Q] .
That's what this guide is for.
2-21
-------
(b) My boss isn't Interested Q .
Do the Hazards Analysis (p. 3-8 ) and show it to him.
(c) There isn't any funding Q . (See (b) above.)
The Hazards Analysis presented to City Council, Board of
Supervisors, or other governing body, can be very effective.
Inquire at the state level; there may be grants. If worst
comes to worst, and all else fails, do what you can AD HOC
(see p. 2-16).
2.7.3 Am I Ready to Start Planning?
(a) Yes, without qualification |~j . Go to page 3-1.
(b) Yes, because I've been tapped to do the job Q .
As an individual? If so, finish up the questions (d) through
(f) below and go on to Section 3, p. 3-1.
(c) Yes, I've been named to be a member of a planning committee Q .
If so, you are probably going to be requested to write a
particular section in which you are expert, Identifying
the responsibilities and capabilities of your organization.
(1) The Committee Chairman is
(name)
(organization)
(2) He is Q] is not Q going to use this planning guide.
Call and find out. If he's not familiar with Lhls
guide, send him a copy.
(3) I know [3] , do not know Q exactly what la expected
of me. If you don' t now, make sure you do^ after you
leave your first committee meeting. You want to know
both FORMAT and CONTENT.
INSIST ON IT!
(d) i have O , have not Q] conducted a Hazards Analysis. If not,
it's the first thing you should do. Maybe applicable ones al-
ready exist. Did you check?
Fire Department? Yes [7] No [~]
Police Department? Yes C] No
2-22
-------
Local Civil Defense? Yes FJ No FJ
State Agencies? Yes FJ No FJ
(Use your telephone!)
Either DO IT NOW ["!
or
Go to Section 3, and make Hazards Analysis the first action of
your planning operation FJ.
(e) I have F] have not FJ selected the type of plan(s) I need.
I am FJ am not FJ still deciding between several different
types (check two or more below, as appropriate).
Telephone Roster FJ
Action Guide FJ
Resource List FJ
Response Plan FJ
Coordination Plan FJ
Ad Hoc FJ (as a last resort, only)
If still trying to decide, go back and reread pages 2-11 to 2-16.
Pay particular attention to the listings in the left-hand
columns to get a feeling for what different types of plans
contain. If that fails, skip ahead to Section 4 (p. 4-2)
and browse through the detailed list of plan contents.
(f) I want to make a plan, but what I want doesn't fit into the
types listed FJ .
Nothing wrong with that. Maybe what you need is a:
(1) Combination O-Do it- Use what you want.
(2) Plan Section FJ (see p. 4-7)
(3) Operating Manual FJ *
* The distinction between a plan and a manual is easiest to define by analogy.
For instance, a fire response plan may call for fire trucks to go to certain
areas to be staged, manned with certain personnel, and commence fighting the
fire when given certain directions. A manual will tell you how to insert
the ignition key in the fire truck, shift the gears, couple and uncouple the
hoses, lock the equipment in the racks, change the tires, maintain the truck
between calls, and so on.
2-23
-------
This guide can still help you if you checked (1) or (2). However,
if you need an operating manual, you want something that this
guide cannot and was never intended to provide you.
(g) I am concerned about disasters because of:
(1) Major Transportation Artery Q any type
(2) Major Chemical Industry/Oil Refinery Q
(3) Major Chemical Use Q]
(4) Major Pesticide/Ammonia Agricultural use Q]
(5) Natural Disaster Potential O any type
Civil Defense people are generally well-informed on disasters and
related subjects.
I have access to a copy of my state/local Civil Defense
Disaster plan. Yes Q No Q
I have contacted my state/local Civil Defense Office to
participate in my planning operation. Yes H] No Q
Name
Telephone
Transportation/Chemical companies in my jurisdiction have been
contacted and invited to participate/provide information. Q]
Contacts: Name
Industry
Telephone
Name
Industry
Telephone
Name
Industry
Telephone
(Insert additional sheets if needed.)
2-24
-------
2-7.4 Yes, I Want a Plan Prepared,
and by my authority I'm going to name the planner/planning committee
chairman. Q]
(a) This is not a cop-out. Q] (Are you sure you shouldn't chair it
yourself?)
(b) The guy I'm naming is qualified because he is:
A skilled planner Q
A good organizer Q
Normally responds to spills, anyhow Q]
In the right department CH Specify:
Understands environmental problems Q]
Will do a good job Q]
Knows the government organization Q, and
Knows everybody he should Q] .
(Did you sneak a look ahead at pp. 3-1 to 3-2 of Section 3?
Maybe you should.)
Other reasons
His Name
Telephone/Location
Send him this guide.
[H GIVE HIM A DEADLINE: Date Due (Be reasonable!)
PROCEED TO SECTION 3 OF THIS GUIDE, OR IF YOU ALREADY KNOW HOW TO SET UP AND
ORGANIZE THE PLANNING OPERATION, GO TO DECISION POINT #2 (p. 3-25).
2-25
-------
3.0 THE PLANNING PROCESS
By now, you should have a fairly good idea of what you want in the way of
a plan, and the question that we propose to answer next is:
HOW DO I GO ABOUT PREPARING THE PLAN?
You may be able to answer that question immediately if:
1. You are skilled in the techniques of planning,
OR
2. You have selected/been assigned something short and simple (tele-
phone roster, checklist, action guide, resource and equipment list).
In these cases, you probably can handle the planning job without going
any further into this guide. Skip ahead to Section 4, and concern yourself
with plan content.
3.1 THE PLANNER(S): WHO AND HOW TO SELECT THEM
As a general rule, documents such as telephone rosters, action guides/
checklists, and resources lists will usually be generated by governmental
agencies in support of or in order to tie into a more comprehensive plan that
encompasses several agencies. These simple types of plans are usually written
by a single individual, and a great deal of experience in planning is not
required.
The more comprehensive plans (response plans and coordination plans) are
usually written for entire communities, districts, or states, and involve the
coordinating efforts of several agencies and departments. In this case, it is
appropriate for representatives from each involved agency to have some input
into the planning process. This set of people becomes the planning group, but
one person with authority and responsibility must still be identified as the
plan coordinator. Depending on how they operate, these people may become a
planning committee, with a planning committee chairman. The distinction:
Coordinator/Group; May never meet; coordinator or working committee
members request (usually by letter) and assemble input from other mem-
bers into final plan; coordinator may draft and send out sections of
plan to appropriate agencies/departments for review and revision.
Chairman/Committee function by a series of meetings; may break down into
smaller groups between meetings; review and revision generally occurs by
direct interaction of members.
3-1
-------
Who should these people be: the individuals group leaders committee
members? The following sections will tell you who to look for.
3.1.1 Individual Group Coordinator Committee Chairman
Your first choice should always be a qualified planner if such can be
identified as part of your local government or within a group or agency. Most
types of planning experience, including urban planning, natural disaster plan-
ning, and financial planning, will provide the basic planning approach. Few
individuals have actual experience in environmental emergency response plan-
ning for hazardous material incidents, but the important thing is to find some-
one who is well-versed in sound planning concepts. If possible, the selected
planner should also be aware of all functions of the community, group, or
agency that needs the plan, but this should not be a prime requirement.
If your organization or community is too small or organized in such a
way that it doesn't include a planner as such, your next best choice is a good
organizer. Look for people who carry that tag; it's generally well known who
they are. Experience in heading up groups and committees, regardless of their
purpose, and in successfully discharging those leadership duties, generally
goes along with being a good organizer. People who have a reputation for get-
ting the job done in complex group situations are what you are looking for.
It may sometimes be the case that a key individual has superior knowledge
of the total working structure of an entire town, county, state, etc., includ-
ing key contacts within each governmental sub-unit. Then, this person may be
in the ideal position to write an emergency response plan or a coordinating
plan for an area. In a case such as this, this key person would not assume an
autonomous role, but would become sort of a chief coordinator being supported
by planning information provided by personnel from within each involved agency.
Look for someone who's known for his ability to expedite government or commu-
nity actions; someone who has a reputation for "knowing the ropes."
If there is an Ad Hoc plan already functional in your area, the guy who
fills the leadership role in that plan might be who you need. You may be
treading on delicate ground, however (see p. 2-16 earlier for comments on "Old
Joe"). This person is probably active in response, and a guy who gets things
done, in the physical sense. A good response team leader (on-scene coordin-
ator) is not necessarily a good planner. On the other hand, his Ad Hoc plan
could be an excellent base for a response plan. Test the waters. Even if the
guy drags his feet, or obviously doesn't belong in the planning role, he might
make a good chief advisor (and give him adequate recognition, if he takes that
responsibility).
If you've already been tapped to do the plan, chances are that you'll
fall into one of the three categories above. Identify yourself, and do what
you do best. Use this guide to supplement your own strengths, and you will
be able to turn out a pretty good plan.
3-2
-------
3.1.2 Planning Groups and Committees
Planning groups are usually involved with developing emergency response
and coordinating plans. It is typical for the group to consist of representa-
tives from key agencies and organizations who have functions assigned to them
in the plan. This representation is needed so that there is no doubt as to an
agency's duties, response capabilities, and policy.
What agencies and organizations should be represented in the planning
process? Table 3-1 lists some agencies that you might want to include. The
list only gives suggestions; membership of a planning group may be greater or
less, but care should be taken not to make a committee so large as to become
unwieldy. You may want to delegate planning authority to a few of the more
involved groups and have the remaining groups be in a support position and
review the final plan document. If you have prior experience with leading or
chairing a group or committee from your particular government level, think
back to it, and use whatever worked best.
Keeping in mind the distinctions between a group and committee that were
made earlier, we recommend the following procedure for having both a dynamic
and comprehensive planning operation.
Establish BOTH:
A Group
Large and Comprehensive
Does Not Meet Routinely
Provides ADVICE AND INPUT
A Committee
Small and Select
Meets Regularly
Provides ACTION AND OUTPUT
Basically, what you want to do is set up a committee to write the plan
(Action and Output), and a large bank of brains that can be picked for infor-
mation and assistance (Advice and Input). There are many names for this type
of operation (-"the working group," the "task force," the "subcommittee," etc.,
etc.); call it whatever you like, it will generally get the job done.
Recommended Committee Members are as follows:
1. The Committee Chairman, selected as described above.
2. Representatives of:
a. "The Lead Agency": This will be the agency/department that has
been or will be designated to be in charge on the scene in the
event of a spill. It may be (and probably will be) one of the
response groups listed next.
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TABLE 3-1. SUGGESTED GROUPS AND AGENCIES FOR EMERGENCY PLANNING
Municipal
County
State
PRIMARY GROUPS
City Manager
Mayor or Representative
Emergency Management or
Civil Defense
Fire Department
Police Department
Public Works
Water
Sanitation
Flood Control
Roads
Waste Disposal
Health Department
Major Industry
Representative
Representatives from
Volunteer Organizations
Key Representatives
from Bordering Cities
County Representative
Citizens Service Group(s)
County Executive
Chairman, Board of
Supervisors or
Representative
Emergency Manage-
ment or Civil
Defense
Fire Department
Sheriff's
Department
Public Works
Water
Sanitation
Flood Control
Roads
Waste Disposal
Health Department
Major Industry
Representative
Representatives
from Volunteer
Organizations
Key Representa-
tives from
Bordering Counties
State or Regional
Representative
Citizens Service
Group(s)
Governor's Representative
Emergency Management or
Civil Defense
Fire Department
State Police
Environmental Resources
Transportation Department
Special Districts
Flood Control
Waste, Sanitation, etc.
Health Department
Major Industry
Representative
Representatives from
Volunteer Organizations
Key Representatives from
Bordering States
Federal Representative
Citizens Service Group(s)
(continued)
3-4
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TABLE 3-1 (Continued)
Municipal
County
State
SECONDARY GROUPS
Welfare Department
Recreation Department
Hospital
Schools
Utilities
Other Service Agencies
Other Service Groups, etc.
Planning Department
News Media Representative
(local newspaper)
Welfare Department
Parks Department
Hospital
Schools
Utilities
Other Service
Agencies
Other Service
Groups, etc.
Social Services
Fish & Game Department
Education Department
Utilities
Other Service Agencies
Other Service Groups, etc.
Planning Department Planning Department
News Media
Representative
(newspaper, radio)
News Media Representative
(news, radio, TV)
b. The Response Agencies: Those groups who are actually going to
have to perform some function. Minimum are:
Fire
Police
Public Works (be sure WASTE DISPOSAL is included)
c. The Interface Agencies: These will hook up your plan with the
existing plans:
Civil Defense
County or State Agency (Sheriff, Environmental Protection,
Public Health, and/or?)
3. A Reviewer (if appropriate, see p. 5-1)
4. An Editor (may be the committee chairman)
3-5
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Keep the committee small. Let the committee members contact other agen-
cies (group members) and involve them as the plan is developed. Maintain a
committee/group separation in your mind. Each is important, but don't let one
interfere with the workings of the other.
Sometimes, the committee can be even smaller if people end up with several
roles (for example, the committee chairman is from the fire department, which
is also designated "Lead Agency"). CAREFUL. If this person can handle it all,
that's fine; just make sure he isn't overloaded, and the plan gets delayed or
downgraded as a result.
Many small communities, operating with volunteers in many government roles,
will look at the above list and see their total qualified manpower resources
listed there. In some instances, this is good, since these same people are
probably working together all the time anyhow, and they can get this job done
just like they get others done. However, there can also be a lot of problems
in this situation, not the least of which is finding the time. Some others
are addressed later (p. 3-7 ).
3.1.3 Consultant
Hiring a consultant to write your contingency plan may be the best choice
to make if you are confronted with any of the- following situations:
You have a manpower shortage.
. Your plan involves some specialized technical knowledge.
/
You simply cannot identify someone who feels qualified to plan.
If you are pressed for time, the consultant approach may not gain you any-
thing. It takes time and commitment to work with a consultant to ensure a
good product.
Of course, consultants charge a greater hourly rate than your salaried per-
sonnel so you must determine whether a consultant will be cost-effective in the
long run.
You will also want to make sure that you pick the right consultant for the
job. Try to locate consultants who have done similar projects in the past, and
carefully review their proposals to make sure you will get-what you want. De-
termine whether you want them to write all of the plan, or just the technical
portion. .Consultants may not know the "ins and outs" of your political struc-
ture, and may not recognize the subtleties involved in effective agency
coordination.
Where do you look for consultants in your area? Check to see what engi-
neering or environmental consulting firms have done work or have written envi-
ronmental impact statements in your area. Question neighboring cities, coun-
ties, states, etc., for their knowledge of consultants. You may even find the
ideal consultant in your own back yard: a retired, high-ranking government
official with the desire, time, and know-how to do your plan.
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3.1.4 Prime Planning Problems The Individual(s)
When a single or a few persons are assigned the task of writing a plan,
there is sometimes the danger that the plan will not be complete; not all
appropriate information or input will be included in the plan. Also, the plan
may be slanted or biased, unknowingly, by the authors, to reflect their own
views and opinions that may not be the consensus of the planning area. These
problems can be mitigated if the planner(s) remains in close contact with all
the involved groups and "flushes out" questionable areas with appropriate groups
early in the planning process. Frequent review of on-going work by the in-
volved agencies is another good idea. A good final review, with the checklist,
is a "must" if a single individual is doing the planning. See p. 5-1.
3.1.5 Prime Planning Problems The Group/Committee
Group planning will most likely ensure a comprehensive planning effort,
but there are some pitfalls that need to be avoided in the group process.
Groups tend to work at a relatively slow pace, and this is probably due to a
variety of reasons. The progress of a committee is usually limited by its
slowest member, e.g., when planning input is delayed by one member, then the
entire planning tempo is stalled until that one effort is completed. A good
committee chairman will be alert and step in when help is needed.
Also, committee planning meetings, a necessary element of the planning
process, often do not make the best use of available time. Meetings can be
long-winded and unproductive if planning members bog down on inappropriate
side issues. (Chairman: You must act in these situations I) It sometimes
happens that when several agencies or groups sit down at one table, the meet-
ing can become a forum for expressing political differences and other griev-
ances fueled by long-standing interagency rivalries. The classic case, almost
unavoidable, is the "traditional" police-fire rivalry, yet you will definitely
need both police and fire department representatives, since they are key
response agencies.
This guide attempts to offer no blanket solution to these group and com-
mittee problems, because there isn't any. Each planning committee chairman
will have to handle his own situation. The intent of this section of the plan-
ning guide is to bring to your attention the possible types of problems to be
encountered so that they may be anticipated. However, some suggestions are
given later (pp. 3-22 to 3-24)-
There are a number of good books on running effective meetings, group
dynamics, and so on. We found the three listed below to have some good ideas.
You can probably find some others in your own library.
Group Discussion and Decision Making, John Hasling,
Crowell Co., New York, NY, 1975
Leadership and Dynamic Group Action, George M. Beal,
Joe M. Bohler, and J. Neil Randobaugh, The Iowa State
University Press, Ames, IA, 1962
3-7
3T»~798 0 82 -
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You and I Have Got to Stop Meeting This Way, Richard J.
Dunsing, Amacom, New York, 1978.
3.2 DUTIES AND RESPONSIBILITIES OF PLANNERS
Once the planner or planners have been established, it is time to get
down to the business of planning. The following sections will give direction
to finding, organizing, and coordinating information that will go into a plan.
There are many ways to accomplish these tasks. If you have your own
accepted planning methods, then you might want to stick with what works best
for you and only review the following sections for informational content. But
if you are new to contingency planning, the following sections should outline
a methodology for getting you from Point A you know you have a plan to
write to Point B the pen is in your hand and you are ready to start
writing.
3.2.1 Hazards Analysis
Basic to your planning, no matter how simple, is an understanding of the
problems that you might anticipate. We recommend:
1. Hazards Analysis as the first step in planning
2. Including the hazards analysis as part of the plan
Even the simple telephone roster type of plan should be backed up by an
analysis, and it should be documented in an accompanying letter when the ros-
ter is distributed.
A Hazards Analysis:
Lets you know what to expect
Prevents planning down blind alleys
Gives you an incentive
May show you where you need "an ounce of prevention"
May open doors and pocketbooks for you (see p. 2-22)
Creates awareness for new hazards
Identifies the commitment you'll require
Tells the type of help you'll need
This last is particularly important if you are in a growing community, and one
more reason why it should be a part of the plan.
You should understand the differences between hazards, vulnerability, and
3-8
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risk, since you may hear any and all of these referred to as things to ana-
lyze. Sometimes INCORRECTLY the terms are used interchangeably.
HAZARD: Any situation that has the potential for doing damage to life,
property, and/or the environment
VULNERABILITY: The susceptibility of life, property, and/or the environment
to damage if a hazard manifests its potential
RISK: The probability that damage to life, property, and/or the
environment will occur if a hazard manifests itself
A good Hazards Analysis will consider all three of these things, but we ad-
vise you to emphasize hazard and vulnerability, and be very careful in attempt-
ing to determine risk. Even very sophisticated techniques, based on such
approaches as "fault-trees" and "event-trees" can lead to a lot of controversy
(and wasted time and effort). There can be so many factors involved in deter-
mining risk that you can bog down and get diverted into problems that are not
the ones you really ought to be working on. The plans you prepare are going
to be based on the assumption that you want to be ready, no matter how small
the risk.
A stepwise procedure for hazard analysis follows, and details of what to
include are given on p. 4-27 as a part of Plan Content. We recommend doing
as complete a hazards analysis as your time and capabilities permit. But,
even if you do only the simplest form of analysis, D(3 ^T_! And do it first'.
There are three basic parts to a Hazards Analysis dealing with potential
spill situations:
1. What do you have?
2. Where is it (or where does it pass through)?
3. What can it affect, and how?
We suggest the following approaches to getting the hazards analysis done:
1. Assign the job to a fire/police team. They generally already have
considerable information about community business, accidents, and
the like, and this is information you need.
2. If the team doesn't already have such information, then consult local
industry. A suggested list is given later (p. 4-27 to 4-28).
3. After identifying potential sources and transportation routes, map
them. Use both street maps (to show where population is affected)
and topographical maps (to indicate flow and drainage patterns).
If you are dealing with a large geographical area, heavily populated,
you may have to break this up into a set of maps. Pre-fire planning,
done by many fire departments, may have already generated maps of
this type. Check with the fire department.
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4. Identify particularly vulnerable or sensitive areas on the same map
(see PP. 4-28.to 4-29).
5. Consult records (newspapers, police/fire, civil defense records) for
actual spill incidents (no.matter how small) and spot them on the
map.
6. Make a written description of what the map shows; pay attention to
any obvious pattern, such as areas of concentration of known spills,
clusters of industrial use or production, storage, and so on. Then
add to this writeup the results of 7, 8, and, 9 below.
7. Estimate the probability of future'spills, IF YOU CAN. This is the
toughest job of all. Don't try to give numerical-answers; use simple
categories ("low, medium, high,"- or even "likely, unlikely"). Some
guides are:
a. Past spills evident = high probability
b. Major trucking route = high probability
c. Major industrial concentration = high probability
d. Concentration of auto accidents = high probability
e. Concentration of railway problems = high probability
Be careful. You have now entered the realm of risk analysis. Do not
equate a low probability with absolute safety. A single filling sta-
tion in your town means that a truck containing thousands of gallons
of flammable liquid will be rolling through your streets in the dead
of night. A single drum of spilled insecticide could mean the con-
tamination of every well in your farm community. There is always a.
finite possibility of having a spill, no matter who or where you are.
If you have had no prior spill problems, you might consider consult-
ing the records of nearby areas similar to your own to see what
problems they've had. It can happen here.
8. Decide what would happen if some of your high-probability spills took
place. That is, their impact on whatever you've identified as sensi-
tive and vulnerable. This is obviously an exercise in speculation,
but don't get carried away. Scenarios can be useful, and try to con-
sider the secondary effects (traffic blocked, business closures, man-
power drains) as well as the direct problems of spill control.
9. Finally, decide what would happen in the event of a disastrous spill
situation. There are two things to consider: a really large spill
and all its complications, and a natural disaster's (fire, flood,
earthquake) effect on the ability to cope with the accompanying
spills. Contact Civil Defense; they probably have already carried
out a hazards analysis that will give you a picture of the potential
for a natural disaster striking your area.
3-10
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Time and resources will probably dictate the depth and extent to which
your hazard analysis is carried out. At one end of the spectrum will be the
case where the fire/police team simply gives their assessment based on what-
ever knowledge they already have; at the other end, you might conduct an in-
dustry survey, develop a picture of local transportation patterns with ship-
pers, and go through a long set of "what if" scenarios to assess your vulner-
ability. DO YOUR HAZARD ANALYSIS, no matter what. Even the simplest sort of
analysis will be a great help in focusing the rest of your planning effort.
Some cautionary notes on your dealings with local industry: Don't let
your zeal for identifying hazards turn into a witch hunt. Too much emphasis
on risk can lead you into this trap. Remember hazard, vulnerability, and
risk are three different things, and things can be ranked as hazards par-
ticularly a technological hazard but be surrounded by so many safety con-
straints that the risk involved is quite low.
Local industry is a rich resource; work with it and take advantage of it.
Things to look for in local industry that can help you are:
Technical experts
Cleanup, recycling capabilities
SPCC (Spill Prevention Control and Countermeasure) and other types of
plans with which you might interface
Training, safe handling instructions
Participation in developing your plan (particularly in defining how
to handle spills on company property)
After your hazards analysis is complete, USE IT. It should be able to
help you decide the following things:
1. The type of plan you want
2. How much detail you need
3. What types of response to emphasize
4. Where to locate response and cleanup resources
5. The type of help you'll need to get, if you can't provide it yourself
3.2.2 Review Prior Plans
A check should be made to determine the existence of current or even out-
of-date emergency response plans or information. These plans can take the
form of mutual aid agreements, planning guides, action guide/checklists, nat-
ural disaster plans, and ad hoc and formal spill response plans. The source
of these plans can be from nearby communities, county, state, and federal agen-
cies, planning authorities, industry, and volunteer organizations. The
3-11
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specific groups or agencies to contact regarding plans are listed in Table 3-2.
The main r.eason for obtaining and reviewing these plans is to develop an
awareness of current emergency planning and response information in order to
minimize work efforts which have already been done and to ensure proper inter-
action with other plans (see Section 3.3). It may be helpful to obtain a plan
from a region that has similar size and hazard potential characteristics as
your planning area. Elements of this plan may be applicable to your area, or
the plan may inspire you as to what should be in your own plan. However, it
is undesirable to rely exclusively on other plans when preparing your own plan
(see p. 3-24, "The Model Plan"). Every planning area has unique qualities and
characteristic problems that must be addressed from a "grass roots" level, an
effort that cannot be achieved by copying other plans.
3.2.3 Response Planning: Identifying Functions
Of Emergency Response or Support Groups
All organizations capable of providing immediate active and material sup-
port in the event of a hazardous chemical spill must be identified. If you
are doing the planning as an individual, use your phone to determine who can
do what. As a starting point, contact the organizations at your level, and
the next highest level listed in Table 3-2. These groups can either provide
direct information or refer you to other sources of information. If you are
working with a planning committee, the key response groups will already be
members of your team, and can probably provide the information directly. If
not, split the list up between them, and let them get the information.
Determine the spill response capabilities of the various agencies. Ask
questions regarding the following topics:
Who would be in charge? (See also 3.2.4 below.)
Personnel assigned: training and skills
. . Equipment available
Environmental emergency response plans and activities (existing)
Defined responsibilities and duties
Existing mutual aid or interagency agreements
Internal chain of command
Once this survey has been completed, organize the data in a tabular or
some other convenient form. This will enable you to make an overall assess-
ment of the spill response capabilities for your area. With a knowledge of
your area's capabilities in hand, you may now be ready to start assigning
planning tasks. However, if you have spotted any deficiencies, you'll have to
do something about them first. Go on and read pp. 3-16 through 3-17.
3.2.4 Coordination Planning: Identifying
Comprehensive Emergency Responsibilities
A comprehensive coordination plan will generally go into the functions of
3-12
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TABLE 3-2. CONTINGENCY PLANNING INFORMATION SOURCES
FEDERAL AGENCIES
STATE AGENCIES
LOCAL AGENCIES
INDUSTRY
VOLUNTEER ORGANIZATIONS
Environmental Protection Agency
Department of Transportation
United States Coast Guard
Federal Emergency Management Agency
Governor's Office
State Environmental Protection Agency
Civil Defense
State Police
State Fire Marshall
State Department of Transportation
County Executive/Commissioners
Mayor/City Council/City Administrator
Civil Defense
Fire Department
Sheriff or Police Department
Public Works Department
Roads
Water Supply
Sanitation
Flood Control
Chemical and Petroleum Producers"
Chemical and Petroleum Storers
Chemical and Petroleum Consumers
Chemical and Petroleum Transporters (Truckers,
Railroads)
Spill Cooperatives
Spill Cleanup Contractors
Waste Disposers
Trade Associations
Professional/Technical Societies
Red Cross
Salvation Army
Church Groups
Local Ham Radio Organizations
Service Groups
government that are important before and after, as well as during, almost any
emergency situation.
Even if you don't do anything else the way this guide suggests, establish
clearly who is in charge; and furthermore, how that responsibility shifts, and
to whom, as more and more resources are called into play. There exists al-
ready a network of plans, right on up to the federal level (see Section 3.3).
3-13
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If you are planning at the local level, you must determine how you fit in so
that it is crystal clear what your limitations are. You must know exactly
how far you can go it alone, and when and for what reasons you are going to
have to have additional support. Among the key responsibilities of the person
you identify as being in charge at the local level will be to know exactly
what his own capabilities are, when he has to call for help, and when he has
to turn the reins over to some higher authority.
Certain governmental agencies have legal responsibility, jurisdictional
authority, a charter, an interagency agreement, or in some other manner have
been delegated a response role in an emergency situation. Therefore, when
planning tasks are assigned, care must be taken to ensure that the assignments
are in accord with legally mandated responsibilities and that there are no
contradictions or unnecessary overlapping of duties.
When sorting out emergency roles in different agencies and organizations,
logic is the key word to be kept in mind. The various necessary emergency re-
sponse functions should be assigned to agencies most logically capable of deal-
ing with them. Some assignments will be obvious, such as law enforcement and
fire protection. However, some duties such as transportation or emergency
public information services may require some deeper searching to determine
which agency or agencies is thought best equipped to handle the situation.
A basic rule should be observed when making task assignments: List all
the jobs that you will need done not just the response tasks first.
Then under those tasks, list the agency or agencies who will do something to
see that the job gets done. Don't do it the other way around.
If you are making a plan for a local community, a state, or a governmental
agency, then primary responsibilities for emergency response tasks should not
be identified as originating from volunteer or other civilian organizations.
This restriction is necessary because civil preparedness is the mandated re-
sponsibility of the government. The efforts of volunteer groups, industry,
and other service organizations should be coordinated through governmental
agencies. In this manner, the civilian groups would have support responsibil-
ities. Such arrangements between governmental and civilian groups need to be
agreed upon prior to plan preparation. The agreements should take the form
of written memoranda of understanding or any other means of expressing mutual
agreement. (See also 3.2.4.1, Coordination With Industry.)
Following is a list of Emergency Responsibilities (Table 3-3). Also in-
cluded in the table are governmental officials or agencies who might be con-
tacted for information and/or input. Your particular planning agency or area
may need to define more or fewer tasks than those listed. If you are in an
area where a civil defense natural disaster plan already exists, then most of
the emergency tasks may have already been assigned to responding agencies.
Coordination with the "in-place" natural disaster plan (see pp. 3-17 to 3-20)
will be required to avoid duplication of efforts or contradictions with exist-
ing plans. In fact, you may find that establishing an interface some sort
of liaison with an existing civil defense plan may eliminate the need for
you to develop a detailed coordination plan of your own.
3-14
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TABLE 3-3. EMERGENCY RESPONSIBILITIES
Law Enforcement Services
. Chief of Police
. County-Sheriff
. State Police Representative
. National Guard Representative
Fire Protection Services
. Local Fire Chief
. Volunteer Fire Chief
. State Fire Marshall
Communications and Warning
. Local and State Civil Defense
. National Guard
. Parks Department
. Fish and Game
. Local and State Police
. Weather Bureau
Damage Assessment
. Tax Assessor
. Records Department
. Public Works Department
Transportation Services
. Dept. of Transportation
. Fleet Supervisors
. Parks Department
. Fish and Game
Emergency Public Information
. Chief Executive
. Mayor/City Manager
. County Executive
. Governor's Representative
. Public Relations Officer
Public Works/Engineering Services Legal Services
City/County Engineer
State Engineer
Public Works Director
County/City Attorney
Attorney General
Utilities
. Public Utilities Representative
. Private Utilities Representative
Health and Medical Services
. City/County Health Officer
. State Health Official
. Nursing Administrator
. Hospital Administrator
Welfare Services
. City/County Welfare Official
. State Welfare Official
Personnel and Financial Services
. Personnel Director
. Finance Director
Rescue Services
. Fire Department
. Police Department
. National Guard
Hazardous Materials
Civil Defense
Fire Department
Environmental Protection Office
Public Works Department
Department of Transportation
U.S. EPA
Coast Guard
National
Contingency
Plan
3-15
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Each task will be identified with a particular lead agency, and other
groups can be added to offer support. The lead agency should be able to pro-
vide for insertion into any plan a list of general actions for which they
will be responsible during emergencies. A compilation of these actions for
all agencies constitutes the plan. The lead agency may also have generated,
for their own internal use, a phone roster and an action guide/checklist that
describes detailed procedures for the agency's response to emergency
situations.
3.2.4.1 Coordination With Industry
Special consideration should always be given to coordination with indus-
try, particularly where there is potential for incidents that will require
responses that are beyond local capabilities. Such capabilities can and
should be arranged, in advance, with whatever industries are appropriate.
Particularly important are arrangements made by local authorities with rail-
ways that have rights-of-way through their communities, where, as with many
other industries, the important point is:
INDUSTRY HAS THE EXPERTS.
The expertise can be made available to whoever needs it, with appropriate
advance coordination. In many complex incidents, the guiding factor should
be technical competence. Dealing with tank car problems, for instance, is an
area where the most competent people are those in the railroad business.
Local response personnel should be prepared to get assistance from industry
whenever they have situations that are unfamiliar, and advance coordination
is a key factor.
3.2.5 Identify Deficiencies
Now that either or both response capabilities/resources and emergency
response task responsibilities have been identified, it's time to determine
whether everything can be done that you feel should be done. Look to see if
all emergency response tasks are adequately covered, and check again with the
appropriate agencies or organizations if you are unsure or if it looks like
something is missing.
If you do spot anything missing, it doesn't mean you should stop your
planning operation. You may have to complete your plan, with the deficiency
called out, and wait for the capabilities of some department/agency to catch
up. You are, however, going to have to make some immediate recommendations
to whoever is in authority. If the missing item obviously falls to some par-
ticular department/agency, then you might:
Simply point out the problem to the agency head, and ask that the
function be taken on
Suggest a rearrangement of duties within or between agencies to
utilize some particularly pertinent resources
Explore entering into mutual aid agreements with neighbors
3-16
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Try utilizing outside organizations, either on a contract or vol-
unteer basis
If the problem requires solution at a higher level, some things you might
suggest are as follows:
Pass a new law or ordinance, or change existing statutes
Appropriate additional monies to emergency response activities and
planning
Look for innovative sources of aid
Seek federal and/or state aid
If all the preceding measures prove technically and politically infeas-
ible or do not pertain to your situation, then adjust the scope of the task
assignments to fit your capabilities. It's better to know what you can and
cannot do, as opposed to having an unrealistic vision of what you would like
to do. The latter tends to discourage emergency planners and gives responders
a false sense of security.
3.3 EXISTING PLANS: INTERFACES, COORDINATING AND USE
Other people have plans. And then some. These plans can be for govern-
mental agencies, industry, counties, cities, states, river basins, air pollu-
tion control districts, regional boards, etc. If your plan is to be compre-
hensive in nature, then it is sure to interface with and be affected by other
plans. As we said before, if you are planning at the local level, this is
particularly important, because you must determine exactly how you will fit
into the system.
Become aware of the other types of plans that are in operation around
you. The local civil defense office is probably one of the most valuable re-
sources for determining how your hazardous chemical emergency contingency
plan would be affected by federal, state, local, industry, and military plans.
However, they may not know everything, so be prepared to look further afield
if it becomes obvious that there is more you need to know. You should check
out the following:
National Oil and Hazardous Substances Pollution Contingency Plan
EPA Regional Pollution Contingency Plan
State Oil and/or Hazardous Material Contingency Plan
State Emergency Disaster Preparedness Plan
RADEF (Radiological Defense) Plans
SPCC (Spill Prevention, Control, & Countermeasure) Plans
3-17
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Co-Op Plans
Industry Emergency Action & Disaster Control Plans
Various Local Plans
Pre-Fire Plans
Police Emergency Plans
Local Agency Plans
Also, there may be many other documents that are pertinent to your particular
situation, and while they are not called plans, they may contain important
information. These include agency alerting procedures, mobilization plans,
mutual aid agreements, agency rosters, and the like.
Also, accidental releases of hazardous materials often cross political
boundaries, thereby affecting multiple communities simultaneously. For these
larger incidents, it is of prime importance that your plan coordinate effici-
ently with the plans of bordering political regions. Therefore, determine
whether your neighbor has a plan, and work with him to make your respective
plans compatible. If you are working at the state level, there may already
be interstate agreements in force.
The following are some of the types of plans you will probably want to
investigate prior to writing your own plan.
The National Oil and Hazardous Substances Pollution Contingency Plan
The National Oil and Hazardous Substances Pollution Contingency Plan
(40CFR1510) is the principal federal mechanism for operations undertaken in
response to pollution discharges occurring in navigable waters, adjoining
shorelines and the high seas of the United States. The "National Contingency
Plan" establishes a federal interagency governmental capability initiating
operational aspects of identification, prevention, containment and cleanup of
oil and hazardous material spills and related mitigation activities. Although
this plan briefly considers environmental damages resulting from pollution
discharges, it deals primarily with operational aspects of mitigation rather
than the broader environmental consequences of spills.
The primary purpose of the plan is to provide a coordinated federal re-
sponse to unexpected, and usually accidental, discharges of oil or hazardous
substances that pose a threat to public health and welfare. The plan sets
out roles and specific responsibilities of federal personnel in the event of
a spill and addresses questions of notification, assessment and direct or in-
direct actions to be taken. The plan also defines various organizations,
structures, and roles (see below). Recent revisions to the plan in 1978 have
identified broader state, local, and industry cooperative mechanisms to im-
prove federal spill response.
3-18
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Definitions:
On-Scene Coordinator (OSC) - the federal official pre-designated by EPA
or the USCG to coordinate and direct federal discharge removal efforts under
Regional Contingency Plans at the scene of an oil or hazardous substance dis-
charge. Local personnel are subject to the direction of, and must clear ac-
tions with, the OSC.
National Response Center (NRG) - serves as the notification center for
pollution incidents in U.S. waters. It is located at the U.S. Coast Guard
headquarters in Washington, DC, and is staffed by Coast Guard personnel. The
toll-free number (800-424-8802) can be reached 24 hours a day, 7 days a week
for reporting of actual or potential pollution incidents. The NRC relays re-
ports to appropriate regional authorities for response actions. Spills can be
reported to this center in lieu of contacting regional Coast Guard or EPA
personnel.
National Response Team (NRT) - is composed of representatives of primary
and advisory agencies. The NRT is responsible for planning and response ac-
tivities for pollution emergencies at the national level. Specific responsi-
bilities and membership are delineated in the National Contingency Plan.
Regional Response Center (RRC) - is the regional site for pollution
emergency response activities. Its location is specified in regional contin-
gency plans. It provides communications, information storage and other nec-
essary personnel and facilities to promote proper functioning and administra-
tion of regional pollution emergency response operations.
Regional Response Team (RRT) - is composed of representatives of primary
and advisory agencies as is the NRT, but in addition, states and possibly
regional and local agencies may provide liaison. Details of representation
are specified in regional contingency plans.
Primary Agencies - departments or agencies comprising the NRT and desig-
nated to have primary responsibility and resources to promote effective opera-
tion of the National Plan. Includes: Commerce, DOD, DOI, DOT, EPA and FEMA.
Advisory Agencies - departments or agencies that can make major contribu-
tions during response activities for certain types of discharges. Includes:
DOE, DHHS, Justice, HUD, and State.
Regional Contingency Plans - plans compiled by the RRTs for planning and
response activities for each Standard Federal Region.
State Plans
It should be determined whether your state has an oil and/or hazardous
material spill plan. This document can provide useful information on state
policy and spill response capabilities that will be valuable when attempting
to interface local, regional, and state agency plans within the overall
state structure.
3-19
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Civil Defense Plans (Disaster Plans, RADEF Plans, Emergency Operations Plan)
It is very likely that your local or state civil defense office has pub-
lished a natural disaster plan for your area. Many of these plans contain
annexes that dictate operational response procedures for hazardous chemical
emergencies involving transportation-related spills or major accidents at
chemical storage or producing facilities. Care should be taken not to dupli-
cate or interfere with the operation of these plans. Determine the best way
to coordinate your plan with the appropriate sections of the natural disaster
plans.
Industrial and Cooperative Plans
Chemical and petroleum products producers, storers, users, and transport-
ers often have spill emergency contingency plans covering their products.
When it is to their mutual advantage, industries sometimes form spill response
cooperatives designed to contain and clean up spills by means of jointly owned
and stockpiled equipment and services. Contingency planners should be aware
of the response services provided by industry and should interface their
plans, when possible, with these services. Be aware of the emergency proce-
dures that industries use to warn surrounding neighborhoods about accidental
chemical releases. See if it is feasible to enter into a cooperative agree-
ment with industry or an established cooperative so that equipment and man-
power can be shared. Be knowledgeable of the spill response technical exper-
tise and response capabilities available from industry, and make active coor-
dination with industry a part of your plan.
It is also important to remember that if a private industry is responding
to a spill or other emergency on his own property (or, as in the case of a
railroad, his own right-of-way), and the spill is confined to that property
or right-of-way, then government, no matter what level, must be careful not to
interfere. A good cooperative agreement will work both ways. It will allow
government to get industry expertise, and will also allow industry to get help
if it needs it. It will also keep industry and government out of each other's
hair until such time as they need each other.
Interfacing
If you need to hook up with any of the above plans and you probably
do make sure you have mapped the channels, and know how to get in and get
through to the proper person(s). You will need some or all of the following:
Who will be in charge, if any action takes place across the interface
Name Telephone Number (+ Alternate)
Knowledge of information you must provide
Knowledge of what conditions require action by state/federal authorities
What enabling actions are needed (disaster declaration, formal request,
approvals, etc.)
3-20
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FIND OUT the keeper of the other plan will be glad to define it for you.
3.4 WRITING AND SCHEDULING
There are a couple of approaches to writing a plan, depending on the
type of plan desired. Telephone rosters, action guides and checklists, re-
source and equipment lists, and sometimes ad hoc plans are relatively narrow
in scope and usually only require one person involved in the actual writing
of the plan. However, response plans and coordination plans are more expan-
sive in scope and comprehension and generally require more persons involved
in the writing task.
When preparing to write a comprehensive plan involving several agencies,
there are a couple of methods to consider:
1. The responsibility for writing the plan may be delegated to one
qualified individual who would work with each involved agency on
a "one-to-one" basis to develop the input for writing the plan.
2. Each agency may write its own section of the plan with the indi-
vidual writing efforts being coordinated in a series of workshop
meetings.
The first method may burden the single writer with an inordinate amount
of work, thus driving the writer into frustration and delay. This approach
does, however, produce a uniformly written package that will measurably cut
down on time spent for editing, a task that will be necessary if the second
approach is selected.
Merits of the second approach result from the inherent advantages of the
group process. The necessary workshops provide a greater opportunity for
awareness, teamwork, and cooperation among those who will be performing cri-
tical emergency response tasks during plan activation.
Consider a series of about three workshops for writing and reviewing the
plan. Schedule the meetings in a realistic manner,.noting the normal working
duties of the persons writing each section. But, it is not wise to stretch
the writing process over too great a length of time. The urgency and moti-
vation for writing can dissipate when excess writing time is allowed.
The chairperson should schedule and set agendas for each meeting well in
advance. The meetings may be patterned from the following outline:
Meeting 1. Assign to the lead and/or response agencies the task of
writing a duties and responsibilities section, "Why and what they
will do during a spill emergency."
Between Meetings 1 and 2, the primary agencies will probably want to
contact group advisory personnel or meet with the support agencies
to further define their respective roles.
3-21
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Meeting 2. Written reports are submitted. Each agency briefs the
group on the contents of its report. Differences are "thrashed out"
and the written sections are finalized. In support of their duties
and responsibilities section, each agency is assigned to write a
section on "How they will perform their functions." This section
will take the form of SOPs, memoranda of understanding, and appen-
dices to the main report.
Between meetings, meet with group advisors or support agencies as
needed.
Meeting 3. Each agency presents a final briefing and submits its
documents for review (see pp. 5-1 to 5-4).
NOTE
The preceding meeting scenario was given only
as an example. Fewer or more workshop sessions
can be scheduled, depending on your own situa-
tion and plan output.
3.5 PROBLEM AREAS AND SUGGESTED APPROACHES
Under most circumstances, the climate for planning will be less than
ideal mainly because PROBLEMS WILL ARISE. This is inevitable when a group of
people get together limited by time constraints, money, personnel, and com-
plicated by differences of opinion and divergences of political views.
As a planning group, the following should be kept in mind when confront-
ing problems:
1. Your common goal is important to the health and welfare of your
community. Every effort should be made to achieve this goal.
2. Solving problems often involves compromises. Remain flexible.
Meet opposing ideas or persons halfway.
The following is a list of typical planning problems, along with possible
solutions for resolving these problems. This entire list should be studied
prior to initiating the planning process. Awareness of problems and solutions
in advance is sometimes a good safeguard against their occurrence.
PLANNING PROBLEM POSSIBLE SOLUTION(S)
Responsibility Prepare interagency or intergovernmental agreements
conflicts
Use a neutral party mediator
Review agency charters to clarify duties and roles.
Revise legislation if necessary.
3-22
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PLANNING PROBLEM
Lack of planning
coordination
Confusion over
regulations
Difficulty in obtaining
plan approval
Excess red tape
Planning/response
personnel turnover
Difficulty in
"identifying technical
assistance resources
Community interest
lacking
Insufficient legal
support
Lack of funding
Setting up planning
organizational
structure
POSSIBLE SOLUTION(S)
Hold frequent planning meetings
Invite more groups into the planning process
Select a planning authority
Select appropriate planners
Follow a planning guide
Obtain higher governmental authority assistance
Pass legislation to clear up confusion
Follow proper plan reviewing procedures (see pp.
5-1 to 5-4)
Review previous planning efforts
Pass an ordinance streamlining planning process
Maintain planning records
Frequently update plan
Schedule regular training exercises
Follow a planning guide
Obtain planning assistance from a higher authority
Publicize a hazards analysis
Hold public hearings
Pass local/state ordinances
Obtain state/federal planning assistance
Finance planning through bonds, taxes, or other
charges
Review civil defense planning procedures
Determine type of plan desired
Determine a planning authority
Issue a planning directive
3-23
3711-798 0 82 - 5
-------
PLANNING PROBLEM
POSSIBLE SOLUTION(S)
Setting up planning
organizational
structure (cont'd)
Lack of full-time
planning commitment
Failure to tailor plan
to local needs
Difficulties planning
for a large
constituency
Problems maintaining
the planning schedule
Determine current planning capabilities
Select appropriate planners
Follow a planning guide
Locate additional funding sources
Obtain state/federal planning assistance
Hire a planning consultant
Adjust scheduling
Perform a hazards analysis for the area in question
Forecast community needs
Identify resource needs and availability
Hold a series of public meetings
Use third-party mediation to resolve conflicting
views
Clearly define planning priorities
Select a planning authority to establish a firm
schedule
Maintain hazardous material contingency planning
as a high-priority item in the community
3.6 THE MODEL PLAN (IT'S NOT RECOMMENDED)
Planning is hard work, and it may seem like there is an easy way out.
You can ignore the rest of this planning guide, and take the model plan ap-
proach. Find a plan where all you have to do is fill in the blanks, and go
to it. Or borrow a plan from a neighboring community, change the name from
"East Weston" to "West Easton," stick in a few phone numbers, changes, and
you're done. BUT be aware of the pitfalls. There are plenty of model
plans, but there is no such thing as a model community. By using a model,
you run the risk of missing something, or of defining some function incor-
rectly, because your community is going to have something different from the
model. In order to avoid getting trapped, you have to take a lot of things
into consideration.
Complacency it's difficult to read through a well-written model
without getting lulled by it.
3-24
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Generality model plans tend to be general; you need to know the
specifics for your community. A well-written general statement can
make you believe something is all set up and arranged, when it really
isn't.
Reliability your plan will only be as complete as the one you're
following, plus your own ability to spot any omissions. You also
have to spot things that the model includes, but which your commun-
ity doesn't have. Then you have to decide where those functions
belong.
We recommend against the model plan, but we'd rather see you following
a model plan than doing nothing. However, to do a really good job with a
model may be just as much work, if not more, than following this guide.
IF (AND ONLY IF) YOU'RE SURE THE MODEL PLAN IS THE ONLY THING FOR YOU
DO IT'. But please, be careful!
3.7 DECISION POINT #2
3.7.1 How Do I Go About Preparing the Plan?
(a) Planning is my business. I am a planner,
so I know how j~j . (discipline, department)
Go to Section 4, and start to work.
(b) I'm a good organizer. Any good organizer can plan FJ .
O.K. Have you decided:
(1) As an individual? Yes FJ No FJ
(2) With a group? Yes FJ No FJ
(3) As a committee chairman? Yes |[ No ||
Maybe you should look at the appropriate
parts of Section 3.
(c) I know the state/county/city/local government (choose one or more)
like the back of my hand, so I can easily put together a plan FJ .
See (1), (2), and (3) under (b) above.
(d) It's easy, because
3-25
-------
If this reason satisfies you, go on to Section 4. Don't mess
with something that you know will work. But are you positive?
(e) I have a model to follow Q] .
BAD! See p. 3-24.
(f) I don't know Q
Stop now, and read Section 3.
(g) I still don't know Q .
Don't abandon the plan!
CU Choose a simpler/less ambitious plan
CU Get an assistant
Q Find another person to do the plan
Q Get a different planning guide (Civil Defense might help)
Q Go to a training course
Q Ask for help! From your boss? Colleagues? Another
branch/department?
Q Hire a consultant (see p. 3-6)
(h) I'm going ahead with the plan, but I can't decide between the
group/committee approach, or whether I should just do it as an
individual Q] .
Read pp. 3-1 to 3-8.
Q Individual, because
(most important reason)
Committee/group, because
(most important reason)
Still undecided. Read pp. 3-22 to 3-24.
3-26
-------
(1) The individual approach will give me a real tough problem,
so I'm going with the group/committee FJ .
(2) Vice-Versa F] .
(i) I'm ready to go, and I understand all about groups and committees,
and who I want working on the plan FJ .
Q The more the merrier. Good Luck.
D Groups and committees are all the same. Oh? (see p. 3-3)
Q I've selected and arranged for
[_J Lead Agency Representative
II Response Agency Representative(s)
Fj Interface Agency Representative
LJ Reviewer
D Editor
(Did you forget someone? See p. 3-3 )
L~] An Advisory Group
(j) I'm ready to go, and I understand all about
L~] Reviewing Prior Plans (p. 3-11)
FJ Hazards Analysis (p. 3-8)
{~j Response Planning (p. 3-12)
Q Coordination Planning (p. 3-12)
L~] Identifying Deficiencies (p. 3-16)
L~] Interfacing with Existing Plans (p. 3-17)
Q~] Getting Down to Writing (p. 3-21)
If so, continue. If not, read where it indicates.
(k) I won't have any problems. Yes FJ No FJ
Do you know what to expect? (See p. 3-22.)
F] Rivalries
F] Responsibility Conflicts
3-27
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Q No Coordination
Q Confusion over Regulations
Q] Red Tape
Q Personnel Turnover
C] No Resources/Can't Find Them
Q No One Really Cares
D No $
O Trouble Getting Organized
d No Full-Time Planners
O No Time to do it
I| Doesn't Fit my Town
C] My City's Too Big
n Schedule Slipped
O I Just Thought of Another One
3-28
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4.0 PLAN DEVELOPMENT AND CONTENT
4.1 PLAN TYPE
If you have already decided on the type of plan you want, then skip to
page 4-2. However, if you still aren't absolutely sure what kind of plan you
should be making, then you might first)
-------
If you are still undecided, you will just have to learn more about plans.
Read the next part on "Plan Content," and then try again.
4.2 PLAN CONTENT
Assuming that the plan type has been determined, it is time to outline
the kinds of information each plan will contain. Included in the following
list are the major sections found in contingency plans, a brief description of
the contents of these sections, and an indication of the types of plans to
which each section is applicable. It is not mandatory that all plans contain
the sections indicated. The list has been developed to provide to planners a
set of guidelines mapping out what can be included in different types of plans.
The subject headings are listed in the general order that is recommended
for their inclusion in contingency plans. The EMERGENCY RESPONSE NOTIFICATION
section should always be placed on the plan front cover or on the first page
in order to facilitate access to this vital information. It should also be
repeated in the body of the plan, since front covers get torn off and lost,
particularly if the plan is one that sees a lot of field use. (See p. 4-8
and 4-17.)
Section
Emergency Response
Notification
Record of Amendments
Letter of Promulgation
Foreword/Pref
ace
Content
Emergency 24-hour
telephone number
Emergency notification
information
- Location of spill
- Material spilled
- Time of spill
- Danger present
- Actions initiated
- Etc.
Change record sheet
- Date of change
- Recording signature
- Changes made
Statement of Plan Authority
Preliminary remarks
- General background
information
- Planning philosophy
- Intent of document
Applicability
Action Guide/
Checklist
Response Plan
Ad Hoc Plan
Telephone Roster
All Plans
Response Plan
Coordination Plan
Response Plan
Coordination Plan
4-2
-------
Section
Content
Applicability
Acknowledg ment
Table of Contents
Introduction
Emergency Response
Operations
Emergency Assistance
Telephone Roster
Identification of plan
contributors
List of topical sections,
figures and tables
Introductory information
- Abbreviations and
definitions
- Purpose/Objectives
- Scope
- Policy
- Assumptions/planning factors
Notification of spill
Initiation of action
Coordinate decision-making
Containment and
countermeasures
Cleanup and disposal
(if spiller is not doing so)
Restoration
Special considerations
- Response personnel safety
- Wildlife protection
Affected agencies
Technical and response
assistance
- Sequence
- Alternate telephone
numbers
- Radio contact
Public and private
support groups
Response Plan
Coordination Plan
Response Plan
Coordination Plan
Response Plan
Coordination Plan
Response Plan
Action Guide/
Checklist
Telephone Roster
Resources and
Equipment List
Response Plan
Ad Hoc Plan
Coordination Plan
4-3
-------
Section
Legal Authority
and Responsibility
Response Organization
Structure/
Responsibilities
Disaster Assistance
and Coordination
Procedures for Changing
or Updating Plan
Plan Distribution
Spill Cleanup Techniques
Disposal/Recycling
Resources
Laboratory and
Consultant Resources
Content
Authorizing legislation
Mandated agency responsi-
bilities
Response Organization
- Chain of command
- Assigned duties
Use of outside resources
- Response capabilities
- Contingency plans
Predetermined arrangements
Responsibility
Change notification
procedures
Change frequency
List of organizations
receiving plan
- Governmental agencies
- Industry
- Volunteer groups
- Other involved groups
Description of cleanup
methods - use Guidelines
Resource listings and
telephone directory
- Cleanup and disposal
services
- Materials and equipment
Telephone directory of
technical support services
- Laboratories
- Private consultants
- Scientific groups
Applicability
Response Plan
Coordination Plan
Response Plan
Coordination Plan
Response Plan
Coordination Plan
All Plans
All Plans
Coordination Plan
Response Plan
Coordination Plan
Ad Hoc Plan
Resources and
Equipment List
Coordination Plan
Response Plan
Telephone Roster
Telephone Roster
Response Plan
Coordination Plan
Resource/Equipment
List
4-4
-------
Section
Technical Library
or Bibliography
Hazards Analysis
Documentation of
Spill Events
Hazardous Materials
Information
Training Exercises
Content
. List of references
- Specific references
- Technical information
- Maps
. Probable hazards
- Pollution sources
. Vulnerable locations
. Frequency/probability analysis
. Identification of high-risk
areas
- Wildlife
- Recreational
- Historic
- Archeological
. List of required reports
. Justification for reports
. Report formats
. Technical information
- Chemical and physical
properties
- Toxicity
- Measurement techniques
. Local hazardous materials
. Transportation placarding/
labeling
. Methods for maintaining
awareness of emergency
response duties
- Case studies
- Simulated exercises
Applicability
Response Plan
Coordination Plan
Response Plan
Coordination Plan
Response Plan
Response Plan
Response Plan
Coordination Plan
In order to start deciding what to include in your specific plan, go now
to Table 4-1, which shows which plan sections are either recommended or op-
tional for inclusion in the various types of plans. You may want to check the
boxes in Table 4-1 as you go down the list.
4-5
-------
TABLE 4-1. RECOMMENDED/OPTIONAL PLAN CONTENT
Sections
Emergency Response Notification
Record of Changes or Amendments
Letter of Promulgation
Foreword/Preface
Acknowled gment
Table of Contents
Introduction
Emergency Response Operations
Emergency Assistance
Telephone Roster
Legal Authority and Responsibility
Disaster Assistance and Coordination
Procedures for Changing
or Updating Plan
Plan Distribution
Spill Cleanup Techniques
Cleanup/Disposal Resources
Laboratory and Consultant Resources
Telephone
Roster
R
R
NA
NA
NA
NA
NA
NA
R
NA
NA
0
0
NA
R
R
Action Guide-
Checklist
R
R
NA
NA
NA
NA
NA
R
NA
NA
NA
0
0
NA
NA
NA
Resource-
Capabilities
List
NA
R
NA
NA
NA
0
NA
NA
R
NA
NA
0
0
NA
R
0
Response
Plan
R
R
0
0
0
R
R
R
R
0
R
R
R
R
R
R
Coordination
Plan
R
R
0
0
0
R
R
0
0
R
R
R
R
0
0
0
o
o
fti
3
4-1
CO
i -
4J
rl
,
4J
t-l
CU
r^J
a
L/
0
0)
-------
TABLE 4-1 (Continued)
Sections
Technical Library or Bibliography
Hazards Analysis
Documentation of Spill Events
Hazardous Materials Information
Training Exercises
Telephone
Roster
NA
NA*
NA
NA
NA
Action Guide-
Checklist
NA
NA*
NA
NA
NA
Resource-
Capabilities
List
NA
NA*
NA
NA
NA
Response
Plan
R
R
R
R
R
Coordination
Plan
R
R
R
0
R
o
0
w
3
(If plan is actually
to be written, check
under type it most
closely resembles.)
* While a Hazards Analysis is not included in these simple plans, it should
still be carried out prior to preparing them. Consider distributing the
hazards analysis in an accompanying letter when the plan is distributed.
4.3 DETAILED PLAN SECTIONS
The contents of each plan section will vary, depending on the type of
plan and the planning level. As a general rule to follow, the higher the gov-
ernmental authority issuing a plan, or the larger the area covered by the plan,
the more comprehensive or the greater the length of each section will be. As
an example, a hazardous materials spill plan for a city would contain a tele-
phone roster with listings of local response personnel, local resources, and
numbers for state or county assistance. Federal assistance telephone numbers
would not necessarily be listed unless a strong federal program is in opera-
tion in an area. In most cases, federal telephone listings would be included
in a more comprehensive plan such as state oil and/or hazardous material plans.
Many people will know what they want and what they can reasonably expect
to include in a plan once they have reached this point in the guide, particu-
larly if they have assessed their capabilities for either response or coordin-
ation planning (see pp. 3-12 to 3-16). For those who would like some addi-
tional guidance, we define three planning levels, as follows:
Minimum Plan Content Those recommended elements of each plan
that should always be included
Major Plan An extensive plan with all major elements of response
included
4-7
-------
Comprehensive Plan Incorporating in detail all major elements of
both response and coordination
Suggested criteria for these planning levels are:
The Minimum Flan Content level of planning is appropriate for local agen-
cies or small to medium communities whose environmental emergency role is
response-oriented. The prime purpose is to create a plan that gets the job
done within the confines of local budgets and capabilities. These are presumed
to be limited and clean lines of communication must be left open to regional or
state authorities for support.
Major Plans are for major population centers or state regional authori-
ties or agencies who will want to consider planning in terms of both their own
immediate mission and as a support to others within their jurisdiction. As
well as being response-oriented, this planning level produces a plan with well-
developed, comprehensive sections and strong coordinative ties to state assis-
tance agencies.
Comprehensive Plans should be developed at the State level. Plan con-
tents should strive for maximum completeness, be geared toward major incidents,
and be well coordinated with federal response capabilities. This plan may be
too bulky for field use, and subsidiary plans (rosters, action guides, resource
lists) should be considered.
Checklist Those who like a still more definitive picture of what ele-
ments should be included at various planning levels are referred to the Check-
list, Section C.
4.3.1 Emergency Response Notification (Front Page Notification)
This section is designed to provide the plan user with a quick handle on
emergency response telephone numbers and hazardous chemical spill reporting
information. The content of the initial spill report is often extremely crit-
ical. Incomplete or nonfactual information transmitted at the beginning of a
spill event can lead to improper response and delays that can threaten public
health and the environment to a degree more than necessary.
This emergency response 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.
The following is a sample of the type of information included on an emer-
gency response notification page. You may wish to use part or all of this
information, or generate new reporting information to suit your own needs.
4-8
-------
24-Hour Emergency Response Hotline Telephone Number
Emergency Reporting Information
- Caller's name, telephone number, identification
Location and source of spill
Material spilled
This is
the least
you should
try to re-
port
- Time of spill
- Spill quantity
- Area and/or waterbody endangered
- Personnel at scene
- Actions initiated
- Shipper/manufacturer identification
- Container type
- Railcar/truck identification numbers
- Placard/label information
Other Agencies to Notify Immediately
4.3.2 Record of Amendments or Changes (See also Section 5.0)
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 changes made, and the signature of the person making the change.
It is also a good idea to include a notice of where to report changes on this
same sheet.
4.3.3 Letter of Promulgation
This letter is mainly a statement of the legal authority responsible for
putting the plan into action. The letter is usually signed by the chief exec-
utive for the area the plan covers.
4.3.4 Foreword/Preface
This section may be included to express certain types of preliminary or
introductory information that will not be addressed in the main body of the
4-9
-------
plan. This type of information may consist of general background information
or a statement of what the plan intends to do.
4.3.5 Acknowledg, ment
Within this section, you may wish to identify and congratulate specific
members of the planning and response teams.
4.3.6 Table of Contents
The TABLE OF CONTENTS section is self-explanatory. Page references
should be used to make sure key sections can be found quickly during emergen-
cies. Critical maps, charts, and figures should also be clearly identified.
4.3.7 Introduction
The content of the INTRODUCTION section is more informational than func-
tional. The more functional elements of the INTRODUCTION will be listed first.
Abbreviations and Definitions
Purpose/Objectives
Scope
Plan Policy
Assumptions/Planning Factors
You may choose not to include all these items since some of them may be cov-
ered in other parts of your plan.
4.3.8 Emergency Response Operations
The actions taken to respond to a hazardous chemical spill are outlined
in this section. The response operations are broken up into 11 phases:
I. Notification of Spill
II. Required Federal Notification
III. Initiation of Action
IV. Coordination of Decision-Making
V. Containment and Countermeasures
VI. Cleanup and Disposal
VII. Restoration
VIII. Recovery of Damages
IX. Followup
X. Special Response Operations
XI. Agent-Specific Considerations
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Each response phase is not a discrete response action which is entirely
independent of all other phases, but for'grouping purposes for this guide, the
preceding list will be used. Several phases may occur simultaneously and may
involve common elements in their operation. For example, during containment
and countermeasures you may indeed be using cleanup and disposal techniques as
part of containment operations.
I. Notification of Spill
The discovery of a hazardous material incident may be made at any time by
a variety of persons: carrier, shipper, manufacturer, government worker, or
bystander. It is necessary that these people have at their disposal a 24-hour
telephone number to convey preliminary emergency spill information to the
proper governmental agency. The type of information to be reported includes
the following:
Type of aid required
Name, telephone number, and identification of caller
Person to contact on scene
Time of spill
Location of spill
Spilled material
Behavior of material reactions observed
Source of spill
Weather conditions/local terrain conditions
Population of area
Personnel at scene
Volume of spill
Anticipated movement of spill
Actions initiated
Water bodies or streams involved
Shipper/manufacturer
Chemical placarding/labelling information
Container type
Railroad/truck ID numbers
The sections of the plan should
1. Repeat and reinforce any items you listed on the Front Page Notifi-
cation (see p. 4-8 )
2. Offer any explanations, discussion, or special comments on the items
above that are appropriate to your area
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3. Add any items that you decided not to include on the Front Page
Notification, but which are obviously important to know about in the
early stages of the spill situation
4. Be descriptive tell about how you want the act of notification
carried out as well as list the items above
II. Required Federal Notification
800-424-8802
800-424-8802
800-424-8802
Any spill of oil or designated hazardous material must be reported to the
above number, which is maintained by the U.S. Coast Guard. Make sure that
either the spiller has done this, or designate it a specific duty of someone
on the response team.
The designated hazardous materials have been listed by the EPA in the Code
of Federal Regulations 40CFR116-119. There are about 300 such materials. Your
best bet is to make sure any oil, oil product, or chemical spill is reported,
and worry later whether it's on the list or not.
III. Initiation of Action
Before actually responding to a hazardous material incident, there are
certain actions that must be taken to establish a firm base of operations. In
this section, the following actions should be covered:
Establish on-scene authority who's in charge
Establish command post and communications network
Identify material (from labels, shipping papers, placarding, CHEMTREC,
the railway STCC system, etc.)
Determine hazard threat (public health and environmental)
Warn public
Activate emergency response teams
Establish priorities (public health, environmental)
IV. Coordination of Decision-Making
In any response, chances are there will be at least two agencies involved
(local police and fire personnel). In major incidents there can be 10 or more,
as the resources of state and federal level are needed, and these levels begin
to exercise their responsibilities through various agencies. Experts may be
called from industry to provide assistance. Work out in advance, to the
greatest extent possible, the following:
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FIRST & FOREMOST, who will be in charge
What will be the chain of command
Who will maintain the command post
When and to whom will the on-scene authority pass to another level
Who will have advisory roles
Who will have the technical say-so on response actions
How do the principals keep each other informed
Who is to make public statements
Who (if anyone) will have veto power
V. Containment and Countermeasures
Actions taken during this phase are directed toward controlling the imme-
diate spread of the hazardous materials. Depending on the type of spill, some
or all of the following procedures may be employed and should be identified
in this plan section:
Fight fire (if any) avoid hazard to firefighters, and let it burn
out if prudent
Shut off source, whenever feasible
Predict spill movement
Contain the material (using any of the response techniques mentioned
in the SPILL CLEANUP TECHNIQUES section)
Contact spiller
Contact spilled material manufacturers
Hire a cleanup contractor
Perform surveillance activities (in support of Phase VI and VII
actions)
VI. Cleanup and Disposal
During this response phase, polluting substances are removed from the
spill area using the types of methods listed in the SPILL CLEANUP TECHNIQUES
section (pp. 4-23 to 4-24). Remember, it is the spiller's responsibility, by
law, to clean up. A government agency should not interfere if the spiller is
acting responsibly. Other actions to be considered in this section include:
Determine spill cleanup responsibility
Determine availability of approved disposal sites
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Consider reclamation/recycling of spilled material
List temporary storage sites
List cleanup funding sources
VII. Restoration
The purpose of this response phase is to restore the environment, to
such an extent as practical, to natural conditions. Actions to be documented
during this phase include assessment of damages, determining restoration
guidelines, and replanting, restocking, etc.
VIII. Recovery of Damages
This section of the plan, which deals with the recovery of cleanup costs,
should cover some or all of the following items:
Investigative requirements (monitoring procedures, photographs,
witness statements, etc.)
Reimbursement procedures
Legal ability to recover damages
Determination of liability
Methods for resolving disputes
IX. Followup
This section explains the use of post-spill monitoring data and other
scientific reports for updating spill response procedures.
X. Special Response Operations
Safety of response personnel, wildlife cleanup and protection techniques,
and special region-specific problems are documented in this section. The
response personnel safety section should include a discussion of recommended
safety equipment and personal hygiene activities.
XI. Agent-Specific Considerations
Depending on the results of your hazard analysis, you may want to in-
clude guidelines for response personnel to use in developing action proce-
dures for the following material:
Oil and petroleum related substances
Hazardous chemicals
Etiological (disease-causing) agents
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Radioactive materials
Oil and related petroleum products have received the most attention, and many
specific response actions are available and well documented (see p. 4-23).
In general, fire departments are prepared to cope with the fire hazard inher-
ent in these materials. However, they may not be acquainted with or prepared
to operate under the guidance of containment, which should be applied if at
all possible. The Coast Guard handles huge spills involving tankers, and
industry cooperatives have been established in most major port and refinery
cities to cope in these areas. Producer and processor sites all have SPCC
(Spill Prevention, Control & Countermeasure) plans for oil, as mandated by
federal law. Any guidelines you establish should be consistent with this
existing system, so you must establish just how the existing system affects
and works in your particular area, and how to tie into it.
Hazardous chemicals will vary from area to area. The best guidelines
for response to such materials are generally derived from the industry that
manufactures them. As we have indicated many times, establish a rapport and
a good working relationship with any industry in your area. Guidelines for
specific materials of interest can also be obtained from a number of the ref-
erence works cited later (p. 4-26). Use of CHEMTREC (p. 4-31) as an on-the-
spot information source, and activation of chlorine and pesticide response
teams through CHEMTREC should be a part of your guidelines. On land, large
quantities of chemicals travel in railroad tankcars, so be sure to include
railroad company contacts in developing guidelines.
Etiological agents For disease organisms or highly toxic substances,
guidelines must be established that will center around protecting the health
of both the public and of response workers. Preventing spread, dissemination
or proliferation of such agents should be the guiding principle. Local and
state public health departments represent the best resource for establishing
such guidelines, and for providing information on the need for specific re-
sponse capabilities in your area. The Center for Disease Control (CDC),
Atlanta, GA, is responsible for any federal response to the health aspects
of toxic environmental exposures and emergencies. However, the.CDC will act
only if there is a clear request from state and/or local health authorities.
Make sure this is understood by anyone concerned with response; a direct call
to CDC will be treated as "information only," or simply as an alert, pending
contact from the appropriate public health agency. CDC has provided clear
guidelines to such agencies, defining their capabilities in response and
technical support in emergency situations.
Radioactive materials Again, as with the etiological agents, guide-
lines must center around the health and safety of both the public and re-
sponse workers, and preventing spread, dissemination or proliferation of the
material has to be a guiding principle.
The area of response to radiological emergencies is already well devel-
oped and highly complex. Again, you must establish where you fit in. At the
state level, there are generally RADEF (Radiological Defense) plans and oper-
ations that originated via Civil Defense, but which may be delegated to other
agencies for action. State civil defense offices usually provide guidelines,
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and guidelines may also be obtained from FEMA (see below).
The Department of Energy and the Nuclear Regulatory Commission (NRC)
also provide guidance to states in emergency planning for fixed nuclear facil-
ities (power plants, etc.)- Two NUREG documents, and a recent joint FEMA/
NRC report may be used for such planning. In addition, the EPA has provided
"Protective Action Guidelines" for general use.
Several important guides are provided by DOT, including the interim
edition of an action guide for responders to transport accidents (see below).
Active response teams are in place at the state level, and also via
interstate agreement (for instance, the 15 Southern States, under the South-
ern Emergency Response Course, have developed the Southern Mutual Radioactive
Assistance Plan), and at the federal level. The latter provides for
IRAP Interagency Radiological Assistance Plan that uses primarily De-
partment of Energy and Department of Defense capabilities to provide assist-
ance and guidance in radiological emergencies. These are generally accessed
through the nearest DOE or military installation.
There are a numberof guides and planning documents available in this
area, as follows:
CPG-6.1, Radiological Defense Preparedness. Federal Emergency Manage-
ment Agency, Publications Office, Room 406, 1725 Eye Street, NW,.
Washington, DC 20472.
NUREG 00931, Handbook for Federal Assistance to State and Local
Governments. Nuclear Regulatory Commission, Division of Document
Control, Washington, DC 20555 ($3.50).*
NUREG 75/111, Guide and Checklist for Development and Evaluation
of State and Local Government Radiological Emergency Response
Plans in Support of Fixed Nuclear Facilities. Nuclear Regulatory
Commission, Division of Document Control, Washington, DC 20555
($3.25).*
NUREG 0654; FEMA-REP 1 - Criteria for Preparation and Evaluation
of Radiological Emergency Response Plans and Preparedness in
Support of Nuclear Power Plants. Nuclear Regulatory Commission,
Division of Technical Information and Document Control, Washington,
DC 20555 (free), or Federal Emergency Management Agency, 1725 Eye
Street, NW, Washington, DC 20472.
Regulatory Guide 5.56, Standard Format and Content of Safeguards
Contingency Plans for Transportation. Nuclear Regulatory Com-
mission, Division of Document Control, Washington, DC 20555 ($1.50).*
A Review of the Department of Transportation Regulations for Trans-
portation of Radioactive Materials. U.S. DOT, Materials Transportation
* Checks payable to: Director, Division of Technical Information.
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Bureau, Washington, DC 20540.
Response to Radioactive Material Transport Accidents. U.S. DOT,
Materials Transportation Bureau, Washington, DC 20590.
EPA-520/1-75-001, Manual of Protective Action Guides and Protec-
tive Actions for Nuclear Incidents. U.S. EPA, Office of Radiation
Programs, Washington, DC 20460.
4.3.9 Emergency Assistance Telephone Roster
An accurate and up-to-date emergency telephone roster is an essential
item of any response-type contingency plan. All phone numbers should be veri-
fied by periodic calls checking to see that telephone numbers and personnel
are still current.
A comprehensive telephone roster is shown on the next page. It is very
likely that you will not need all numbers listed. Choose the phone numbers
most appropriate to your situation for inclusion in your plan.
4.3.10 Legal Authority and Responsibility
In many cases, planned responses to hazardous material spills have been
established as a result of laws, statutes, ordinances, etc. These laws usually
provide the legal muscle to do some or all of the following:
Authorize preparation of a plan
Require spill notification
Determine liabilities
Impose penalties
Require cleanup
Define governmental responsibilities
Appropriate funds for spill cleanup
This section gives the opportunity to explain what laws are in effect,
who has the authority to enforce them, and what are the mandated responsibil-
ities of government.
If writing a plan for a community, you will probably want to include all
local ordinances dealing with spills, and any pertinent state legislation. If
you wish, you might even make reference to the National Oil and Hazardous Sub-
stances Pollution Contingency Plan (40 CFR 1510) that encourages the formation
of contingency plans at the local level (1510.42).
State contingency plans will want to reference appropriate state laws and
federal laws and regulations, such as Section 311 of P.L. 92-500 (the Clean
Water Act) and 40 CFR 1510, respectively.
4-17
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SAMPLE TELEPHONE ROSTER
Contact/Alternate
Business/Home Phone
Community Assistance
Police
Fire
Civil Defense
Environmental Protection Agency
Department of Transportation
Public Works
Water Supply
Sanitation
Rescue Squad
Ambulance
Hospitals
Utilities
Gas
Phone
Electricity
Community Officials
Mayor
City Manager
County Executive
Response Personnel
On-Scene Coordinator
Agency Coordinators
Response Team Members
Bordering Political Regions
Cities
Counties
States
River Basin Authorities
Interstate Compacts
(Note: If there are 24-hour
numbers, or special time
restrictions, so indicate.)
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SAMPLE TELEPHONE ROSTER (Continued)
Contact/Alternate Business/Home Phone
Bordering Political Regions (cont'd)
Regional Authorities
Industry
Transporters
Chemical Producers/Consumers
Spill Cooperatives
Spill Response Teams
Volunteer Groups
Red Cross
Salvation Army
Church Groups
Ham Radio Operators
Off-Road Vehicle Clubs
Etc.
Media
Television
Newspaper
Radio
State Assistance
Environmental Protection Agency
Civil Defense
Department of Transportation
Police
Public Health Department
Military Department
Federal Assistance
U.S. Dept. of Transportation (DOT)
U.S. Environmental Protection Agency
4-19
3T»-T9a 0 82 - 6
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SAMPLE TELEPHONE ROSTER (Continued)
Contact/Alternate Business/Home Phone
Federal Assistance (cont'd)
Federal Emergency Management
Agency
National Response Center 24 hours 800-424-8802
Center for Disease Control -
Contact via State/Local
Public Health
U.S. Army
Nuclear Regulatory Commission
Radioactive Material
Emergency Response
Other Emergency Assistance
CHEMTREC 24 hours 800-424-9300
CHLOREP 24 hours 800-424-9300
NACA Pesticide Safety Team 24 hours 800-424-9300
Bureau of Explosives (AAR)
Bomb Disposal and/or Explosive
Ordnance Team, U.S. Army
Poison Control Center
Cleanup Contractor
4.3.11 Response Organization Structure/Responsibilities
The purpose of this section is to describe the emergency response groups
and organizational structure, spill response center operations, and the duties
of key response personnel. The following is a listing, by governmental level,
of the various types of hazardous material spills response operations. Pick
the groups appropriate for your planning level and area and include clear def-
initions of their activities in your plan. To obtain correct information, you
may need to make inquiries to appropriate emergency response or planning
agencies.
Federal (Refer back to Section 3.3 for a discussion)
National Response Center
National and Regional Response Teams
On-Scene Coordinators
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Environmental Response Team (EPA)
National Strike Force (Coast Guard)
State
State Response Center
State Response Teams
On-Scene Coordinator
Local
Local Response Center
Local Response Team
On-Scene Coordinator
In addition, emergency response groups and individuals such as coordinat-
ing committees, agency coordinators, and public information officers should be
described. It is important, when defining the duties of the public informa-
tion officer, that the news media release policy is clearly explained to ensure
quality and accurate reporting.
4.3.12 Disaster Assistance and Coordination (See also pp. 3-17 to 3-21)
This section should indicate where assistance can be obtained when the
operating emergency response system becomes overburdened during a hazardous
material emergency. Pre-arrangements for assistance can be made with higher
level governmental agencies, bordering political regions, industry, spill
cooperatives, and provisions for interfacing with other contingency plans
(either hazardous material or natural disaster) can be made.
It is important to be familiar with the civil defense disaster plan cov-
ering the area in question. When spill events or hazardous material emergen-
cies reach disaster magnitudes or when a natural disaster threatens to compli-
cate a hazardous material spill, governmental authorities must know who to
contact to receive disaster assistance from the civil defense sector. This
section should describe the mechanism for coupling with disaster plans.
Any coordination with outside agencies should be formalized through mutual
aid agreements or memoranda of understanding specifying delegation of author-
ity, responsibility, and duties. These agreements can be included in the plan
if desired.
4.3.13 Procedures for Changing or Updating Plan (See Section 5.0 for more
details)
This section provides the mechanism for ensuring that plan contents are
kept in a correct and up-to-date manner. Accurate plan information is neces-
sary for swift and efficient emergency response actions.
Responsibility should be delegated to someone to make sure that the plan
4-21
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is updated frequently and that all plan holders are informed of the changes.
Someone should periodically (at least every six months) check to see if stock-
piled resources are available as indicated in the plan.
Notification of changes should be via some type of written memorandum or
letter, and the changes should be recorded on the RECORD OF AMENDMENTS page.
4.3.14 Plan Distribution
The plan distribution list should account for all organizations receiving
copies of the plan. This information is essential when determining who should
be sent revisions and updates to the plan. Also, it is important for each
group on the list to be aware of who has access and reference to the plan.
This awareness will promote coordinated spill emergency readiness and response
among the various organizations.
The following is a sample distribution list. Specific organizations will
need to be listed for your planning area under some of the headings, but you
will not want to include all the organizations indicated, since the distribu-
tion list will depend on the level and comprehensiveness of your plan.
DISTRIBUTION LIST
Federal Agencies
Environmental Protection Agency
Coast Guard
Corps of Engineers
National Weather Service
Federal Emergency Management Agency
Nuclear Regulatory Commission
Department of Commerce
Department of Transportation
State Agencies
Environmental Protection Agency
Civil Defense
Department of Transportation
Governor's Office
Public Health
State Police
Interstate Agencies
County Agencies
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Municipal Agencies
Volunteer Groups
Industry
Chemical Manufacturers
Chemical Processors
Chemical Users
Petroleum Companies
Railways
Truckers
Others as Appropriate
Spill Cooperatives/Mutual Aid Groups
Bordering Political Regions
4.3.15 Spill Cleanup Techniques
Spill cleanup techniques are included in plans to provide emergency re-
sponse field personnel with the proper methods for cleaning up and disposing
of spills. Listed in this section are some of the most commonly used types
of cleanup methods. Concentrate on the techniques that are applicable to the
hazardous materials and terrain of your area. It may be helpful to include
sketches and details on how cleanup should occur for certain areas where
spills are expected.
The following references will give some background information on clean-
up, containment, and fire prevention techniques:
Manual for the Control of Hazardous Material Spills: Volume 1
Spill Assessment. EPA-600/2-77-227.
Emergency Handling of Hazardous Materials in Surface Transportation.
Bureau of Explosives, Pamphlets 1-4, Association of American Railroads.
Fire Protection Guide on Hazardous Materials, 7th Edition. National
Fire Protection Association.
Hazardous Chemical Spill Cleanup 1979, J. S. Robinson (Ed.). Noyes
Data Corporation, Park Ridge, NJ, 1979.
In addition to these references, local fire departments, environmental
emergency response agencies, and spill control training courses should be
consulted for more information. Also, the ASTM (American Society for Testing
Materials'), through its F-20 committee, is developing standards and guidelines
for the various technological aspects of spill control.
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If it looks like these techniques are beyond your local capabilities,
consider a cleanup/disposal contractor. It may be possible to make standby
arrangements with such a private company to provide needed services. None of
these techniques should be attempted by other than trained and qualified
personnel.
Every year, the U.S. EPA and the U.S. Coast Guard sponsor a National Con-
ference on spill control, with the emphasis alternating each year between oil
and hazardous materials. The presentations at these meetings provide the lat-
est in information on control and cleanup techniques. An accompanying exhibit
provides a showcase for manufacturers of equipment and service organizations
to display their wares.
4.3.16 Cleanup/Disposal Resources
This section is similar to the yellow pages of the telephone book. It
informs plan users of three important pieces of information:
What types of resources are available (public and private)
How much is stockpiled
Where it is located (address and telephone number)
This section of the plan should include such resource items as:
Cleanup/disposal contractors and services provided
Cleanup material and equipment
Communications equipment
Emergency transportation (aircraft, four-wheel vehicles, boats, etc.)
Cleanup personnel
Personal protective equipment
Approved disposal sites
This information can be gathered by sending to appropriate groups and
agencies a questionnaire requesting the desired information. The question-
naire should be followed up or verified by a personal or telephone interview.
Organizations that may have resources for use during a hazardous material
incident include:
Public agencies (fire, police, public works, Fish & Game, etc.)
Industry (chemical producers, transporters, storers; spill cleanup
contractors; construction companies)
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Spill/equipment cooperatives
Volunteer groups (ham radio operators, four-wheel vehicle clubs, etc.)
Resource availability will change with time, so keep this section of the
plan up to date.
4.3.17 Laboratory and Consultant Resources
The scientific community can be a valuable source of technical informa-
tion during hazardous material spill emergencies. Technical experts can pro-
vide such services as advice on chemical toxicity, reactivity, and environ-
mental damage, and public and private laboratories may be equipped to perform
chemical analyses for monitoring purposes or for determination of unknown
spilled substances.
This section should identify the various scientific groups capable of
providing technical support, the persons at these facilities to contact in
an emergency, and the services available. Places to contact with regard to
this type of information include:
Colleges or universities
Local health department
Private or industrial laboratories
Private consultants
Government-supported laboratories or research institutes
4.3.18 Technical Library
Much information has been published on hazardous materials, hazardous
material spills, and contingency planning. For an emergency response or
planning organization, it could prove quite useful to maintain a technical
library at a convenient location to serve as a reference source and an in-
structional tool.
This section should simply list the technical references kept on hand.
The reference may be annotated to supply additional information about refer-
ence contents.
The following are some of the types of publications to be included:
General References
- Pertinent laws, legislation, regulations, etc.
- Local and/or state oil and/or hazardous materials contingency plans
- Bordering political region contingency plans
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Spill cooperative/mutual aid contingency plans
EPA technical documents and other scientific publications on oil
and/or hazardous materials
A few selected specific references to be recommended are:
- National Oil and Hazardous Substances Pollution Contingency Plan,
40 CFR 1510
- EPA Regional Contingency Plans
- Emergency Handling of Hazardous Materials in Surface Transporta-
tion, Bureau of Explosives Pamphlets 1-4, Association of American
Railroads
- Disaster Operations. A Handbook for Local Governments. CPG 1-6,
July 1972, Federal Emergency Management Agency, Publications Of-
fice, Room 406, 1725 Eye Street, NW, Washington, DC 20472
* Hazardous Materials Spill Monitoring. Safety Handbook and Chemi-
cal Hazard Guide. Parts A and B. EPA 600/4-79-008a&b
- Managing Hazardous Substance Accidents. Al J. Smith, McGraw Hill,
New York, 1980 (in press)
Fire Protection Guide on Hazardous Materials, 7th Edition, National
Fire Protection Association, 470 Atlantic Ave., Boston, MA 02210
Emergency Action Guide for Selected Hazardous Materials, 1978.
U.S. Department of Transportation, 400 Seventh Street, SW, Washing-
ton, DC, 20590
- Dangerous Properties of Industrial Materials, N. Irving Sax,
Van Nostrand Reinhold Co., New York, NY
- Fire Officers' Guide to Dangerous Chemicals, Charles W. Bahme,
National Fire Protection Association, 470 Atlantic Ave., Boston, MA
02210
* Manual for the Control of Hazardous Material Spills: Volume 1
Spill Assessment. EPA-600/2-77-227
- Guidelines to the Handling of Hazardous Materials, Darrel J.
Behrendsen (Denver Police Department). Source of Safety, Inc.,
8303 E. Kenyon Blvd., Denver, CO 80237.
* Development of an Emergency Response Program for Transportation
of Hazardous Wastes, EPA Report SW-171C
* For EPA report availability, contact Patricia Folker, U.S. EPA, Cincinnati,
OH 45268.
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- Transportation Emergency Action Guides for Hazardous Materials
Incidents (a wall chart).JODY Incorporated, P.O. Box 88884,
Atlanta, GA 30338
- * Land Disposal of Hazardous Wastes. EPA-600/9-78-016
- * Field Detection and Damage Assessment Manual for Oil and Hazard-
ous Material Spills, EPA Division of Oil and Hazardous Material
- A Survey of -Personnel Protective Equipment and Respiratory Appar-
ata for Use by Coast Guard Personnel in Response to Discharges of
Hazardous Chemicals"! NTIS ADA-010-110, National Technical Infor-
mation Service, 5285 Port Royal Road, Springfield, VA 22161
Maps
Land use
- Topographic
- Environmental
- Streams, drainage basin
4.3.19 Hazards Analysis (See also Section 3.2.1, p. 3-8)
This analysis consists of determining where hazards are likely to exist,
what places would most likely be adversely affected, and what is the proba-
bility that a hazardous material incident could occur at a given location. A
detailed method for conducting a hazards analysis was given earlier (Section
3.2.1).
To identify probable sources of hazardous materials pollution, oil and
chemical manufacturers, users, storers, and transporters need to be inter-
viewed, either in person or through a written questionnaire, about their
activities. At the same time, experts can be identified, and the company's
interest in establishing a cooperative agreement, support, assistance in spill
problems, etc., can be established.
Industries to be contacted include:
Farm and Related Industry
- Crop dusting
- Fertilizers
- Pesticides
* For EPA report availability, contact Patricia Folker, U.S. EPA, Cincinnati,
OH 45268.
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Petroleum Industry Chemical Industry
- Bulk consumers - Manufacturers
- Producers - Processors
Oil fields - Distributors
- Refineries - Recycling plants
- Storage facilities ^ Manufacturers (Chemical Users)
- Waste disposers
. . - Rubber
- Refueling facilities
- , - Paint
Bulk terminals
Plastics
. Transporters _ Textiles
- Airway - Soap/Detergents
- Highway - (Many others)
- Waterway . Waste Dlsposal
- Pipeline _ Sanltary wastes
Railway - Hazardous waste
Any written questionnaire should be sent to management-level officials
and be accompanied by correspondence indicating how the information will be
used. The questionnaires should be aimed at learning the following:
Hazardous materials and trade names
Hazardous properties
Product safety information and emergency guidelines
Types of storage/shipping containers
Transportation routes/frequency
Persons to contact for technical assistance
Company spill plans, and possibility of interfacing with community
plans
The next step is to determine at what locations a hazardous material in-
cident would cause the most problems in terms of public health and environ-
mental protection, the first and second priorities, respectively. Questions
similar to the following should be raised:
Are drinking water intakes close to any major transportation artery
or hazardous material facility?
At what sections of the highway are transportation accidents most likely
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to occur? At the narrow bridge over the stream feeding into town?
What sections of the highway are subjected to severe natural elements
(rain, flooding, ice, etc.)?
Historically, what have been the major problem areas?
Are chemical storage, production facilities, or pipelines located in
the flood plain or near earthquake zones?
What natural disasters are common to the area, and is it likely they
will cause or contribute to a hazardous material incident?
These and similar questions need to be asked so that emergency readiness
can be planned. It may be helpful to plan in detail for certain types of ex-
pected emergencies. For instance, cleanup supplies and equipment can be stock-
piled at key locations, evacuation routes can be planned in advance, and spe-
cific response procedures can be practiced in advance. But keep in mind, many
types of accidents may occur besides the most expected ones. Therefore, make
sure plans remain flexible, even though only a few types of emergencies are
common for an area.
In the plan, in addition to whatever maps you might include, it may also
be useful to make lists of the following items for reference during emergency
situations:
Transportation corridors
- Railway
- Airway
- Pipeline
- Highway
Waterway
Oil and Hazardous Material Facilities
- Producers
- Storers
- Consumers
Areas of Public Health Concern
- Drinking water intakes
- Vulnerable population centers
Hospital locations
Schools, playgrounds
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Sensitive environmental areas
- Wildlife habitats
- Parks and recreational areas
Wild and scenic rivers
Historical sites
Archeological areas
4.3.20 Documentation of Spill Events
Written reports are necessary to successfully evaluate a hazardous mate-
rial incident as well as lending support to possible cost reimbursement and
legal action. The following is a list of the various types of reports that
have been used to document hazardous material spill events. From the descrip-
tive information given, choose the reports or parts of reports that are applic-
able to your situation. It is important that all reports be written using a
standard format to facilitate information gathering.
Initial Pollution Incident Report reports the initial specifics of a
spill, e.g., time, location, material and quantity spilled, spiller, source of
spill, public health hazards, agencies contacted, comments, etc.
Chronological Log maintains a minute-by-minute account of spill response
activities, e.g., emergency response team activation, call for state/federal
help, commence sampling of contaminated area, etc.
Final Pollution Incident Report summarizes the total event including
cause of incident, incident critique, damage assessment, expenditures, liabil-
ity conclusions.
Spiller's Report - Spiller's version of the spill incident including
time, cause of spill, material and quantity spilled, location, cleanup actions
taken, etc.
Investigative Report - Foundation for civil action against spiller or
violator. Report includes who, what, why, when, where, how, witness state-
ments, photographs, etc.
4.3.21 Hazardous Materials Information
This section should provide technical support information on hazardous
materials. Information to be developed in this section includes the following:
Listing of common hazardous materials
Hazardous material definitions (49 CFR parts 100 to 199) and
40 CFR 112-116
Technical information
- Chemical properties
4-30
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- Physical properties
- Measurement techniques
- Toxicological data
- Response personnel safety data
- Recommended fire-fighting techniques
Shipping regulations (packaging, labelling, and placarding)
Excellent technical information can be obtained from the following
references:
Fire Protection Guide on Hazardous Materials, 7th Edition National
Fire Protection Association
Emergency Handling of Hazardous Materials in Surface Transportation
Bureau of Explosives Pamphlets 1-4, Association of American Railroads
Emergency Action Guide for Selected Hazardous Materials, 1978 U.S.
Department of Transportation
Hazardous Materials Spill Monitoring, Safety Handbook and Chemical
Hazard Guide, Parts A and B.EPA 600/4-79-008a&b
Information on federal hazardous material shipping regulations is avail-
able from the Material Transportation Bureau of the U.S. Department of Trans-
portation. Also, local transportation or highway departments should be
checked to determine regulations that affect hazardous material transportation.
4.3.21.1 CHEMTREC
CHEMTREC stands for Chemical Transportation Emergency Center, a public
service of the Chemical Manufacturers Association, with offices in Washington,
DC. CHEMTREC provides immediate advice for those at the scene of emergencies,
then promptly contacts the shipper of the chemicals involved for more detailed
assistance and appropriate followup.
CHEMTREC operates around the clock 24 hours a day, seven days a week
to receive direct-dial toll-free calls from any point in the continental
United States through a wide area telephone service (WATS) number, 800-424-9300
(483-7616 for calls originating within the District of Columbia; 202-483-7616
for calls originating outside the continental U.S.).
As circumstances warrant, the National Transportation Safety Board or
appropriate offices of other agencies may be notified.
CHEMTREC is not intended and is not equipped to function as a general
information source, but by design is confined to dealing with chemical trans-
portation emergencies. CHEMTREC should not be called on problems other than
chemical spill emergencies.
4-31
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An emergency reported to CHEMTREC is received by the Communicator on
duty, who records details in writing and by tape recorder. The Communicator
then attempts to determine the essentials of the problem. This is to enable
him to provide the best available information on the chemical(s) reported to
be involved, thereby giving specific indication of the hazards and what to do
(as well as what not to do) in case of spills, fire, or exposure as the imme-
diate first steps in controlling the emergency. Information on the various
chemicals, as furnished by the producers, is within easy reach. Trade names
and synonyms of chemical names are cross-referenced for ready identification
by whatever name is given.
CHEMTREC's Communicators are not scientists. They are chosen for their
ability to remain calm under emergency stresses. To preclude unfounded per-
sonal speculation regarding a reported emergency, they are under instructions
to abide strictly by the information prepared by technical experts for their
use.
Although proceeding to the second stage of assistance becomes more diffi-
cult where the shipper is unknown, the Communicator is armed with other re-
sources to fall back on. For example: Concerning radioactive materials,
CHEMTREC can call on the Department of Energy.
Mutual aid programs exist for some products. Arrangements of this sort
are established on chlorine through the Chlorine Institute and on pesticides
through the National Agricultural Chemicals Association. The former has
CHLOREP, the Chlorine Emergency Plan, in which the nearest producer responds
to a problem. NACA has a Pesticide Safety Team Network of some 40 emergency
teams distributed throughout the country. CHEMTREC serves as the communica-
tions link for both programs.
4.3.22 Training Exercises (See also Section 5.0)
The most important tool in keeping a plan functionally up to date is the
training exercise. These are simulated spill exercises where emergency re-
sponse personnel act out their duties and coordination interfaces are checked
for proper match-up. The exercises can be desk-top/paper types, or they can
be realistic enough so that equipment is deployed, communication gear is
tested, and "victims" are sent to hospitals with simulated toxic exposures.
The purpose of exercises may be threefold:
To test the adequacy of the plan
To train personnel
To introduce new procedures, concepts, or equipment
For a broader understanding of the importance of training and exercises,
the planner should read pp. 5-9 et seq. before completing this section of the
plan.
This section of the plan should establish the following minimum criteria:
4-32
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Authority in charge of training exercise
Frequency of training exercises
Procedure for evaluating training performance and making changes to
contingency plans as necessary (see pp. 5-9 et seq for suagestions).
The nature of training simulations should be related to how often a plan
is used. If the plan is used in response to many real spill situations, then
training exercises should emphasize two things:
New equipment, concepts, procedures, and/or
Uncommon spill situations
This last is recommended because scenarios that simply repeat situations with
which everyone is familiar will not challenge the flexibility and resources
of the plan and the personnel who operate within its framework.
If a plan is used but seldom, then scenarios should also include the most
likely spill situations for your area. Use your Hazard Analysis for a guide.
Remember; A training exercise must be carefully worked out and executed
if it is to be effective. Half-hearted efforts will generate a false sense
of security. Each exercise must be followed with a realistic critique. See
also page 5-8 .
4.4 DECISION POINT #3
4.4.1 What Type of Plan Do I Want?
a. I've already decided. Without question, it will be a:
Telephone Roster Q
Action Guide/Checklist Q
Resource/Equipment List Q
Response Plan Q]
Coordination Plan Q]
Ad Hoc Plan L]
Get on with your plan. Skip to 4.4.2 to decide what to put in it.
b. I could probably decide if:
(1) I knew what was right for my level of government Q]
Read p. 4-1, then go back to 4.4.1, a.
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(2) I had a good idea of what was in each type of plan Q
Read pp. 4-2 to 4-7, then go back to 4.4.1, a.
(3) I really knew a whole lot about what was in each type of
plan Q
Read pp. 4-7 to 4-33, then go back to 4.4.1, a.
(4) I weren't so confused []]
You're probably trying to swallow too much at once.
Go back and rest awhile in the AWARENESS section,
and let the different concepts of WHAT KIND OF
PLAN (pp. 2-11 to 2-16) sink in. Then read Section
4.1, and try again.
c. I'm going to:
(1) Let my boss decide P]
(2) Let the committee decide Q]
(3) Put it to a vote Q
,.. . , and see what they
(4) Ask -t r^rr; : = r
(neighboring town, state, agency)
have Q
(5) Read Section 4.0 and then decide Q
You can guess what we recommend.
4.4.2 What Sections Will the Plan Contain?
a. I know exactly what I want Q
Skip down to 4.4.3. (But if you're just a little unsure,
read Section 4.2.)
b. It doesn't matter, all plans contain pretty much the same thing
You are mistaken. See p. 4-2.
c. I don't know what's meant by "sections" Q
Read Section 4.2 (pp. 4-2 to 4-7).
d. Well, at least it doesn't matter what order they're in [~]
Wrong again. See p. 4-8.
4-34
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e. I wish I had a listing of sections by plan type, so I could
pick what I need FJ
Now you're talking. See Table 4-1 (p. 4-6).
f. I'm going to:
(1) Let my boss decide FJ
(2) Let the committee decide FJ
(3) Put it to a vote FJ
.. x . , and see what they have I I
(4) Ask f T-TT : r ''
(neighboring town, state, agency)
(5) Read Section 4.0 and then decide FJ
We just went through this a few minutes ago.
Remember?
4.4.3 What Will be Detailed in Each Section?
a. I know exactly what I need FJ
Not likely. Keep reading.
b. I'll let the concerned agencies worry about that FJ
Who's going to guide them?
c. The details will be pretty much the same regardless of level of
government concerned FJ
No. See pp. 4-7 to 4-8 .
d. I want to:
(1) Just do the minimum necessary FJ
(2) Develop a hefty plan FJ
(3) Really do a comprehensive job FJ
First, make sure it's right for you (see pp. 4-7 to
4-8).
e. I have a good idea of what I want, because I have already
assessed local capabilities FJ
Probably true. Get on with your planning.
4-35
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f. I just need an outline, then I can decide Q]
See pp. 4-2 to 4-5.
g. Maybe if I had some kind of checklist I could decide Q
OK. Read pp. 4-6 to 4-7 , then proceed as indicated
there.
4-36
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5.0 PLAN APPRAISAL AND CONTINUING PLANNING
5.1 PLAN REVIEW AND APPROVAL
There are a number of approaches to the question,
IS THE PLAN ANY GOOD?
The first step comes immediately after the plan is assembled, completed, and
edited, but before it is Issued, and takes the form of one or more of the
following:
Self-Review
Peer Review
Committee Review
Higher Level Approval
. The suggested use of these techniques for the various types of plans is
shown in the chart below. Look at what you should be doing for your plan,
then skip ahead and read about it.
Plan Type
Telephone Roster
Action Guide & Checklist
Resource & Equipment List
Response Type
Coordination Plan
Ad Hoc Plan
Review Method
Self-
Review
//
/
//
X
X
//
Peer
Review
X
//
X
'
/
X
Committee
Review
X
X
X
//
//
X
Upper Level
Review
OK
OK
OK
'
/
X
/ Minimum Necessary
// Recommended Approach
x Not Appropriate
OK Only if Required
5-1
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UPPER LEVEL REVIEW is always desirable, and in some cases may be
absolutely necessary in order to formalize commitments, agency assignments,
etc. You will have to judge this requirement for yourself.
SELF-REVIEW means going over the finished plan yourself to see if it's
all right. But if it's finished, doesn't that mean it must be all right? In
order to avoid this complacent little trap, a CHECKLIST (p. C-l) has been pro-
vided so you can see how your plan stacks up. USE IT! No matter how simple
your plan has turned out, TRY TO BE HONEST'. Remember, what you are turning
out in the way of a plan could affect lives and property and you live here,
too.
PEER REVIEW means finding someone else to review your plan, who knows
what he's doing. PEER should mean someone with capabilities equal to your own
in contingency planning, but that may be tough to find about now. After all,
you just finished working out a plan, and probably know more than any of your
co-workers about the problems and content of that plan. DON'T just hand the
plan to the guy in the next office and ask him to "look it over." That is not
peer review. The simplest and quickest way to get a reasonable approximation
of peer review is to give your plan and this guide to someone and ask him to
go through the CHECKLIST (p. C-l) for you. Now all you have to do is find the
right person to do that job. Go back (p. 3-2) and look at the qualifications
for selecting people to prepare plans. You want someone who:
Is Honest
Is Objective
Is Conscientious
Won't Nit-Pick
Understands what the plan's all about
If you plan to use peer review on a plan that's being prepared by a com-
mittee, it's wise to try to identify the reviewer early, and include him in
the committee from the very beginning. This will ensure his understanding of
the scope and purpose of the plan.
DO NOT SELECT
A Superior
A Subordinate
A "Yes Man"
Anyone with an axe to grind
A specialist on some part of the plan
You may have to go outside of your own department, or even outside of the
framework of your own government level to find the most appropriate person
(you might even find a True PEER). There's nothing wrong with that. How
about:
5-2
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The safety or environmental engineer in a local industry?
A Principal/Superintendent, local school system?
A College Professor? (May ask consultant fee.)
A concerned citizen's group? (Such groups as the League of
Women Voters and many others provide a high level of objec-
tivity along with the appropriate environmental awareness.)
COMMITTEE REVIEW uses the same committee that prepared and submitted the
individual parts of the plan. This process does not suffer from the "it's
finished, so it's all right" trap that the individual can fall into, because
the committee members are asked to review the total plan (and they will auto-
matically be critical of all parts of the plan except the part they wrote
themselves that's only human nature).
COMMITTEE REVIEWERS should be given the following instructions:
1. Follow the CHECKLIST if it helps you.
2. Be honest, etc. (see PEER listing, above).
3. Do the following, WITHOUT FAIL, even if they do nothing else:
a. If YOU EXPECT SOMETHING (support, response, contact, whatever)
from another organization or person as a part of the action to
be taken, make sure that it's spelled out and understood by that
organization in their part of the plan, or by other identifiable
agreement.
b. If another organization/person EXPECTS SOMETHING OF YOU, make
sure you know what it is, and are prepared to do it.
4. Set a deadline for comments. However, ask any agencies/groups/per-
sons who run into problems in 3a and b above to work out the appro-
priate revision, not just say, "It ain't there," or "we can't do it"
when they turn in their comments.
UPPER-LEVEL APPROVAL generally means, submit something to your boss, see
if he likes it, and get him to "sign it off." Host management-level people
are pretty good at doing this job the way it was meant to be done; after all,
direction, review, and evaluation of subordinates' work is what management's
all about. Make sure your boss has the proper tools to do the review job:
1. If he assigned you the job, remind him of the original constraints
and conditions he imposed.
2. Complete either peer or committee review prior to submission for
upper-level approval and submit the results of that review along
with the plan.
5-3
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3. Suggest the CHECKLIST.
4. Set a deadline (allow enough time). TELL HIM'. "I'd like to have
this back by (date) so we can issue it before (whatever's
appropriate) "
AFTER. THE REVIEW IS OVER, you, as planner, planning committee chairman,
or editor, have to make some final decisions on what to change or revise.
1. Omissions. If there are any, they should be fixed. That's obvious.
2. Additions and Alterations
a. Make sure you are not going beyond what was originally intended.
b. Make sure you aren't adding detail to the point where you're
writing a manual (see p. 2-23).
c. On the other hand, make sure you don't leave something out or
leave something in that's incorrect, just because you don't feel
like reworking part of the plan.
3. Erroneous comments are bound to turn up once in awhile. Someone mis-
understood something. However, check and be sure maybe there's
confusion in the way something's written. English is a deceptive
language.
4. Disagreements between you and the reviewers may occur. Discuss them,
and try to reach a solution. Keep such disagreements out of commit-
tee meetings; save them for private contacts/communications.
After you've been through the review cycle once, GET ON WITH IT. Don't
re-review, distribute results for comment, or otherwise quibble. Make changes,
issue the plan, and start using it. Everything from here should be considered
updating and improving. If anyone is still in disagreement with some part of
the plan, make sure he understands that there will be future opportunities for
change. Be careful: Make sure any leftover disagreements don't interfere
with function. In that case, they have to be cleared up.
5.2 KEEPING A PLAN UP TO DATE
All plans get out of date: people change jobs, new telephones are in-
stalled, new equipment is purchased, old equipment is scrapped, companies go
out of business, department and agency responsibilities change, etc. Keeping
a plan up to date is difficult, unless you have a high frequency of spills,
and the plan gets a lot of use. Interviews with state and local officials
have indicated that plan updating is one of the biggest problems, if not the
single biggest problem, in contingency planning. There is no ready, 100-
percent foolproof solution to this problem, so overkill is recommended. Use
as many of the following techniques as possible preferably all of them
and think up some of your own.
5-4
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1. Establish a regular review period, preferably every 6 months; never
less than annually.
2. Make one person or one department/branch responsible for review.
Choose with reliability in mind.
3. Choose another person, or another department/branch to whom the re-
sults of the review must be reported (in addition to the normal dis-
tribution of changes).
4. Include a "Record of Amendments and Changes" sheet in the front sec-
tion of the plan (see Section 4.3.2). When changes are sent out,
people having copies of the plan should have, as a minimum, spaces
to enter the following:
Date
Pages Affected
Nature of Change
5. Include a "Where to Report Changes" notice in the plan, and a plea
for holders of the plan to report any changes or suggested revisions
to whoever's responsible (see 2, above).
6. Make any sections of the plan that are subject to frequent changes
either easily replaceable (looseleaf, separate appendix, or however
you like), or provide lots of blank space (double- or triple-spaced
typing) so that old things can be crossed out and new things easily
written in. This applies particularly to TELEPHONE ROSTERS and
RESOURCE & EQUIPMENT LISTINGS.
The responsible person/department/branch (2, above) should do the
following:
1. Maintain a list of plan holders, based on the original distribution
list, plus any new copies made or distributed. Since copying mach-
ines abound, it is wise to send out a periodic request to departments/
branches showing who is on the list, and asking if anyone should be
added.
2. Test/check all telephone numbers, persons named with particular re-
sponsibilities, equipment locations/availability, and so on. In ad-
dition, ask departments/agencies to review sections of plans defin-
ing their responsibilities and action.
3. Distribute changes. Be specific ("Replace page xxx with the attached
new page," or "cross out (whatever) on page (so and so) and write in
the following (new phone number, name, location, etc.). Any key
changes (i.e., emergency phone number change, equipment availability,
etc.) should be distributed as soon as it occurs. Do not wait for
the regular review period to notify plan holders.
5-5
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4. Send a periodic letter to all plan holders, even if there are no
changes, and ask them to record it:
Date: whatever
Pages Affected: (None)
Nature of Change: (None: Regular Review)
5. Request an acknowledgment of changes from whomever you send them to.
The best way to do this is to include a self-addressed send-back
sheet ("I have received and entered changes dated . Signed
(whoever)").
6. Attend any plan critique meetings and issue changes as may be re-
quired (see below, p. 5-8).
5.2.1 Computer Techniques: Word Processing
Word processors allow the storage of data telephone rosters, equip-
ment lists, resources plan sections, entire plans and allow the material to
be revised by simply telling the processor what to do, what changes to make,
what to delete or add.
Word processing has the following advantages:
1. It makes revision and update less of a chore.
2. It is rapid.
3. It allows for more frequent updating, even with large plans.
The use of word processing techniques does not change any of the previous
recommendations on plan updating (see 5.2 above). It will only make it easier
for the person or department that is responsible to do the job and that,
of course, is an important thing to consider.
Disadvantages of word processing are:
1. It may not be cost-effective for small plans, unless it can be piggy-
backed onto an existing computer in some fashion, such as by time-
sharing.
2. If large sections of a plan are updated at one time, individual
changes are not readily evident.
- Therefore -
3. A manual backup notification system may be necessary to assure that
key changes are noticed by everyone concerned.
A basic word processing system would consist of the following functional
units:
5-6
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A keyboard entry terminal for manual entry of plan text and sub-
sequent updating of plan data
A storage module (i.e., magnetic cards, magnetic tape, disk) to
archive the plan and allow easy access to the text to make updates
and produce copies
An output device (i.e., line printer, high-quality terminal) to pro-
duce printed copies and updates of the plan
An interactive word processing software package to serve as inter-
face between the hardware devices and the user of the system. This
package should support text input, text modifications, and format-
ting and finished document outputting.
A viable word processing system must provide all of the above function-
ality regardless of the size of the plan to be stored. However, depending on
the physical size of the plan, the actual hardware/software configuration will
vary.
A small plan, e.g., a local agency response plan of some 20 or 30 pages
of text, would require a minimal configuration. A plan such as this would
require storage of approximately 100,000 characters. A requirement such as
this would be served very well by a magnetic card typewriter based system.
By giving careful consideration to the initial layout of the plan, future up-
dating and modifications would be handled very well by this type of system
with a minimal cost to the user.
A large plan, e.g., a comprehensive state, plan and operations manual or
an emergency preparedness plan of several hundred pages requiring frequent
modification, routine updating and frequent access, would require as much as
a million characters of storage. A faster, more versatile system such as a
commercial word processing package based on a full-fledged computer system
would be preferable. The output device should be fast enough to enable a com-
plete copy of the plan to be produced in a reasonable amount of time.
There are several Important considerations when deciding upon the type of
word processing system to be employed. These include, but are not limited to,
cost, functionality, reliability, and frequency of use. In general, an agency
should try to choose a system that fulfills its needs at a minimum cost. How-
ever, the agency should also take into account the availability of qualified
personnel to operate and maintain the system. In many cases, agencies will
find it is more cost-effective to lease or time-share word processing services
rather than purchase and maintain their own system.
5.3 CONTINUING PLANNING
The final question,
HOW DO I IMPROVE MY PLAN?
should always be left open, because planning should never truly stop. The
5-7
S7l»-798 0 82 - 7
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first step in continuing planning was treated separately earlier, because it
is an extremely important and difficult item to deal with:
KEEP UP TO DATE (p. 5-4)
Additional steps in continuing plan improvement are:
INCIDENT REVIEWS AND CRITIQUES
EXERCISES
TRAINING COURSES
INCIDENT REVIEWS AND CRITIQUES should be held after an actual spill or
other problems covered by the plan, and the basic idea is to find out if any-
thing slipped through the cracks. Suggestions on the critique/review follow.
1. Make the person who's in charge of plan updating also be responsible
for conducting the incident review.
2. Let the dust settle before conducting a review. Wait until at least
a week has passed; this gives people a chance to get minor irritations
out of their system.
3. Avoid Critique and Incident Review meetings, unless you know that
everyone who is attending is capable of giving and accepting truly
constructive criticism (very rare'.). Otherwise, you run the risk of
the meeting degenerating into accusations, confrontations, recrimin-
ations, and timid silence, particularly if things got fouled up. And
that's exactly when you need the most feedback after things get
fouled up.
4. Send a questionnaire letter to everyone involved in the spill, ask-
ing for comments and suggestions. Again, it's best if you include
some sort of self-addressed send-back form. Keep responses confi-
dential.
5. Failure to answer your request for comments can itself indicate a
problem. Follow up with a phone call.
6. Look for true plan deficiencies: things that were overlooked, im-
properly identified, or just didn't work the way they were supposed
to
- HOWEVER -
7- Chances are, you're going to get a lot of personal or departmental
deficiencies pointed out in response to your request. Such things as
failure to communicate, slowness to respond, not knowing the job, and
so on, are indeed problems, but not plan problems. Handle them sep-
arately, or let the appropriate people know about them (informally!)
Don't make matters worse by sending out a bunch of finger-pointing
letters.
5-8
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8. Do something about it. If you do uncover a true deficiency, get the
wheels in motion to correct it. (New planning session; request ap-
propriate person/department to rewrite section; revise and re-issue
it yourself.)
EXERCISES/TESTS are simulated incidents that allow you to try out the
plan; they are "dry run" situations. They can range in complexity from a sim-
ple paper and pencil desk-top exercise to a full-scale, real-time mock
disaster.
DON'T EVER IGNORE THE NEED for continuing exercises and training via such
exercises. Mismanagement of incidents can be traced more often to plain ig-
norance lack of training than to anything else. Exercises should be
aimed at letting you always have the answers (the right answers!) to three
questions:
1. Is the plan adequate, or are there holes in it?
2. Are the personnel trained at all levels to function under the
plan?
3. Does everyone understand the latest concepts, procedures, and
equipment?
The last of these is particularly important if there have been changes in
the plan, or new developments (equipment, capabilities, personnel) that re-
quire familiarization.
The extent and type of exercise can be varied to adapt to your particu-
lar plan. If your plan is used in many real spill situations, you will not
test your capabilities by fighting the same war over again. Try to set up
situations that are uncommon. You can use your Hazard Analysis as a guide if
you don't have many actual spills. In this case, you should simulate the
situations you expect most likely to occur.
IT IS PARTICULARLY IMPORTANT to conduct exercises if you have few real
spills. Don't let your plan gather dust in a file drawer, and expect every-
thing to go smoothly the first time you need it.
CIVIL DEFENSE should, if possible, be given charge of conducting tests
and exercises; they generally have been conducting disaster drills, and either
have access to or can adapt an exercise to center around spill situations.
An existing Hazardous Material Exercise of the desk-top variety is available
from FEMA, Region 8, Denver Federal Center, Building 710, Denver, CO 80225.
Ask for "DOWNWIND."
Some notes about exercises:
1. If your plan is already very actively in use, don't repeat actual
situations in exercises.
2. Do have a critique and review meeting, and hold it immediately after
5-9
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the exercise. People tend to discount problems encountered during
exercises, so you want to get to the results as soon as you can.
Chances of dissention between people in this meeting are small. They
already have an adversary (the exercise director) and an automatic
excuse ("Well, it was only a game") for any misadventures.
Again, as after a real incident (see p. 5-8):
Distinguish between
Plan Deficiencies
and
Personal and departmental deficiencies
Do something about plan deficiencies.
TRAINING COURSES can help with continuing planning by:
Sharpening response personnel skills
Presenting latest ideas/techniques
Contact with other people in the business
EVERYONE ON A RESPONSE TEAM MUST BE TRAINED.
EVERYONE DESIGNATED IN THE PLAN SHOULD BE TRAINED
The latter should apply to people at all levels who serve to coordinate,
manage, or have responsibilities under the plan without being directly in-
volved at the scene of an incident. This is the only way that they can have
a full appreciation of the importance of their role and the effect that they
may have on plan functions.
Following is a list of some of the more comprehensive courses available
across the country. (Note: listing of these courses is for information
only; no endorsement by the U.S. EPA or Rockwell International is intended or
implied.) The indicated address and telephone number will allow you to con-
tact someone for detailed information, current fees and schedules. The list
is alphabetical.
Contingency Planning for Hazardous Materials. Five-day course,
lecture and extensive role-playing simulation. Held at the
Institute. Contact: California Specialized Training Institute,
Camp San Luis Obispo, Bldg. 904, San Luis Obispo, CA 93406.
Tel: 805-544-7101.
Handling Hazardous Materials Transportation Emergencies. Three-
day slide-tape-exercise course. (Note: the slides, tapes, exer-
cise books and instructor's manual may be purchased for use as a
5-10
-------
"home study" course.) Goes to various cities. Contact: NFPA
Seminars, Educational Technology Unit, 470 Atlantic Ave. ,
Boston, MA 02210. Tel: 617-482-8755.
Hazardous Materials. Three- or four-day lecture courses. Held
either at the Center or in various other locations. Contact:
The Center for Professional Advancement, P.O. Box H, East
Brunswick, NJ 08816. Tel: 201-249-1400.
Hazardous Materials. Both a three-day awareness lecture course
and a two-week in-depth lecture, demonstration and participation
course are available. The latter is sponsored by the U.S. DOT.
Contact: Colorado Committee on Hazardous Materials, P.O. Box
22533, Wellshore Station, Denver, CO 80222. Tel: 303-289-4891.
Hazardous Materials Training Seminar. Five-day lecture course.
Goes to various cities. Contact: Toxic Substance Control Labor-
atory, Vanderbilt Medical Center, Nashville, TN 37232. Tel:
615-322-4754.
Incident Management; Hazardous Materials. Two weeks, with lec-
tures and extensive simulation and role-playing. Designed for
fire officers. National Fire Academy, Route 1, Box 10A,
Emmitsburg, MD 21727. Tel: 301-447-2501.
Oil Spill Control Course. Five-day lecture, demonstration and
exercise course. Held at Galveston, TX. Contact: Oil and Haz-
ardous Material Training Division, Texas Engineering Extension
Services, The Texas A&M University System, F.E. Drawer K, College
Station, TX 77843. Tel: 713-845-2112 or 845-7621. (Note: Work-
shops, conferences, and courses on other related subjects are also
available.)
Oil Spill Control Training Course. Five-day lecture and demon-
stration course held at the School. Contact: National Spill
Control School, Corpus Christi State University, 6300 Ocean Dr.,
Corpus Christi, TX 78412. Tel: 512-991-8692.
In addition, there are many shorter and/or more specialized courses that
may be available at the State level, presented by the State Fire Academy,
Police Academy, Environmental Control Agency, or other concerned groups. For
instance, the State of Tennessee operates a Hazardous Materials Training In-
stitute providing both general and specific courses on tactics in spill situ-
ations. ASK AROUND:
Many industries provide specialized training or information as a continu-
ing part of their public relations and awareness programs. In particular,
many railways will conduct familiarization and training programs for fire and
emergency service personnel along their rights-of-way. Contact manufacturers,
railways, and local trade associations to inquire. Fees and costs will vary.
An increasing number of companies in the training business now are appearing
on the spill control scene, and you may be able to find textbooks, slide/
5-11
-------
cassette programs, or other courses/course material to fit your needs. You
will have to be your own judge of cost versus benefits.
5.4 DECISION POINT #4
5.4.1 Is My Plan Any Goodl
a. Yes, because it's already functioning Q
Skip down to 5.4.2 below and worry about incident reviews.
b. I think so, but I'm going to have it checked by:
(1) My friend (name)
(2) My colleague (name)
These may not be the right people. See Peer Review
(p. 5-2).
(3) Someone in another department _ (name)
Better. Is he really suitable? See pp. 5-2 to 5-3.
(4) Someone outside our immediate government structure
Name
Organization
Does this person really know anything about spill contingency
planning? Yes Q
NO n
Was he at the original planning meeting: (Told of role then?)
Yes D No D
This person is qualified because
(5) The planning committee Q (p. 5-3)
(6) My boss Q (see p. 5-3)
c. The person/people I've selected above is/are the right one(s),
because this plan is a
Telephone Roster Q]
5-12
-------
Action Guide/Checklist Q]
Equipment/Resource List HJ
Response Plan D See p. 5-1 for
- tI recommendations
Coordination Plan |_J
Ad Hoc Plan D
d. I'm going to check it myself. Yes Q No Q
e. I'm going to use/provide the checklist (p. C-l). Yes Q No Q
If not, why not?
Plan is too simple r~\
Plan is only a roster Q
I know exactly what should be there Q
I don't want to influence the reviewer(s) Q
These are not necessarily good reasons, and you may be making
a mistake.' The checklist is a useful tool. At least take
time to look at it.
f. After the review is complete, I will (choose one):
(1) Make every change the reviewer(s) want(s) F]
(2) Ignore the obviously erroneous Q
(3) Submit the review results for comment |~|
(4) Get the committee back together to hash out any
disagreements Q
(5) None of the above H] . (See p. 5-4.)
This is the preferred answer. Make sure you know why.
5.4.2 How Do I Correct and Improve the Plan?
a. That will occur as a normal and routine function of my
department Q
Don't bet on it.
b. The boss will take care of it Q]
We thought he assigned the job to you.
5-13
-------
c. I told to see to it
(name)
OK, does he know what to do?
d. The following person/branch/department has been identified as
responsible:
Make sure they have seen pp. 5-1 and 5-7.
Sounds good keep going.
e. Are there provisions for:
(1) Regular review periods? Yes [ I No [~~j
How long?
(2) "Record of Changes" in plan? Yes Q No FJ
(3) Plan holders know where and how to report suggested changes?
Yes Q No rj
(The plan should tell them!)
(4) Critiques after actual incidents? Yes PJ No FJ
(5) Exercises and tests? Yes j~] No [~|
(6) Opportunities for training? Yes FJ No f~~]
f. After incidents or exercises, we will
(1) Identify plan deficiencies, and act on them F]
(2) Identify personnel deficiencies, and act on them FJ
(3) Identify department deficiencies, and act on them f~]
(4) Always hold review meetings F]
(5) Send questionnaires f~~]
(6) Try to get everything wrapped up the same day j~]
5-14
-------
(7) This is a trick question Q Right!
If you don't know why, see pp. 5-4 to 5-7,
5-15
-------
PLAN CHECKLIST
Be sure you are familiar with the con-
tent of the Planning Guide before using
this checklist. (See Decision Points
1 through 4.)
C-l
-------
A. PLAN IDENTIFICATION/TITLE
1. Plan is clearly identified (Yes FJ No FJ ) as: (check one)
Telephone Roster O
Action Guide/Checklist Lj
Resource/Capabilities List I I
Response Plan I |
Coordination Plan FJ)
Ad Hoc FJ (may be unwritten)
2. Source of responsibility for plan is clearly shown. Yes FJ No |]
(e.g., agency, county, city, state, department, name of industry)
3. Area to which plan applies clearly shown. Yes FJ No j~J
(e.g., city of , highways of , region )
4. Application of plan clearly shown. Yes FJ No I|
(e.g., hazardous chemicals, oil spills, etc.)
All answers should be "yes."
C-2
-------
B. PLAN VISIBILITY/ACCESSIBILITY
1. Identify plan type.
"""-" "no" in column under plan type opposite rating factor.
2. Enter "yes" or "no1
Plan Type:
(see A)
Rating Factor
Major sections easily identified:
Large, clear headings?
Pages numbered?
Total pages shown? (e.g., 1 of
3, 2 of 3, etc.)
Table of Contents /Index?
Tabs/dividers for each section?
Easy to add/replace sections?
Appendices identified and
purpose clear?
n
CU
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P. CU
CU 4-1
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CU 0
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JUSTIFY ANY "NO" answer in an "R" box!
R = Recommended
0 = Optional
NA = Not Applicable
C-3
-------
C. PLAN CONTENT
1. Plan Sections
a. Identify plan type.
b. Enter "yes" or "no" in box
found.
under plan type to indicate sections
Plan Type:
(see A)
Rating Factor
Emergency Response Notification
Record of Changes or Amendments
Letter of Promulgation
Foreword /Preface
Acknowledgment
Table, of Contents
Introduction
Emergency Response Operations
Emergency Assistance
Telephone Roster
Legal Authority and Responsibility
Disaster Assistance & Coordination
Procedures for Changing
or Updating Plan
Plan Distribution
Telephone I .
Roster " '
R
R
NA
NA
NA
NA
NA
NA
R
NA
NA
0
0
Action Guide- . .
Checklist LJ
R
R
NA
NA
NA
NA
NA
R
NA
NA
NA
0
0
Resource-
Capabilities Q
List
NA
R
NA
NA
NA
0
NA
NA
R
NA
NA
0
0
Response i i
Plan ' '
R
R
0
0
0
R
R
R
R
0
R
R
R
Coordination i i
Plan U
R
R
0
0
0
R
R
0
0
R
R
R
R
D
o
£
3
If plan is written, check under type it most closely
resembles.
JUSTIFY ANY "NO" answer in an "R" box!
R = Recommended
0 = Optional
NA = Not Applicable
C-4
-------
Plan Type:
(see A)
Rating Factor
Spill Cleanup Techniques
Cleanup/Disposal Resources
Laboratory & Consultant Resources
Technical Library or Bibliography
Hazards Analysis
Documentation of Spill Events
Hazardous Materials Information
Training Exercises
n
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CU 4-1
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0) O
H Pi
NA
R
R
NA
NA*
NA
NA
NA
Action Guide- , ,
Checklist 1 '
NA
NA
NA
NA
NA*
NA
NA
NA
Resource-
Capabilities rn
List
NA
R
0
NA
NA*
NA
NA
NA
Response I I
Plan L-1
R
R
R
R
R
R
R
R
Coordination I 1
Plan ^
0
0
0
R
R
R
0
R
n
0
o
PC
3
If plan is written, check under
type it most closely resembles.
JUSTIFY ANY "NO" answer in an "R" box!
R = Recommended
0 = Optional
NA = Not Applicable
* While a Hazards Analysis is not included in these simple plans, it should
still be carried out prior to preparing them. Consider distributing the
hazards analysis in an accompanying letter when the plan is distributed.
C-5
-------
2. Section Content
a. Identify planning level (see p. 4-7).
b. Enter "yes" or "no" in box under plan level to indicate sections
found.
Section
Emergency Response
Notification
Record of
Amendments
Letter of
Promulgation
Foreword /Preface
Acknowledgement
Table of Contents
Introduction
Plan Level:
Content
24-Hour Emergency Telephone
Number
Emergency Reporting Information
Change Record Page
Statement of Plan Authority
Preliminary Remarks
Identification of Plan
Contributors
Table of Contents
Abbreviations & Definitions
Pur pose /Objectives
Scope
Policy
Assumptions/Planning Factors
n
L
C rt
H i-H
S PU
R
R
R
0
0
0
R
R
R
D
D
3
n
VJ
0 C
i > (X)
cfl i i
S P-I
R
R
R
0
0
0
R
R
R
0
0
0
Comprehen- i i
sive Plan ' '
R
R
R
R
0
0
R
R
R
R
R
R
JUSTIFY ANY "NO" answer in an "R" box.'
R = Recommended
0 = Optional
NA = Not Applicable
C-6
-------
Section
Emergency
Response
Operations
-
Emergency
Assistance
Telephone Roster
Legal. Authority
& Responsibility
Plan Level:
Content
Notification of Spill
Required Federal Notification
Initiation of Action
Coordination of Decision Making
Containment and Countermeasures"
Cleanup and Disposal
Restoration
Recovery of Damages
Followup
Special Response Operations
Agent-Specific Considerations
Local Assistance
Response Personnel
Bordering Political Regions
Industry
Volunteer Groups
Media
State Assistance
Federal Assistance
Emergency Technical Assistance
Authorizing Legislation
Mandated Agency Responsibilities
Minimum i i
Plan LJ
R
R
R
R
0
0
0
0
0
0
0
I
X
i
X
L
L
0
0
1
0
R
o
1
D
M
0 0
n n)
££
R
R
R
R
R
R
R
R
R
R
0
R
R
R
R
R
R
R
R
R
R
R
Comprehen-
sive Plan LJ
R
R
R
R
R
R
R
R
R
R
R
NA
R
R
J
IV
>
J
X
»
X
X
R
R
R
JUSTIFY ANY "NO" answer in an "R" box!
R = Recommended
0 = Optional
NA = Not Applicable
C-7
-------
Section
Response
Organization
Structure/
Responsibilities
Disaster Assistance
and Coordination
Procedures for
Changing or
Updating Plan
Plan Distribution
Plan Level:
Content
Federal Level
State Level
Local Level
Sources of Disaster Assistance
Mutual Aid Agreements
Responsibility
Notification Procedures
Federal Agencies
State Agencies
Interstate Agencies
County Agencies
Municipal Agencies
Volunteer Groups
Industry
Spill Cooperatives/
Mutual Aid Groups
Bordering Political Regions
Minimum i i
Plan ^
NA
NA
0
R
0
0
0
NA
0
NA
0
0
0
0
0
0
n
M
o £
i) n)
crt i I
S PH
0
R
R
R
0
R
R
0
R
0
R
R
R
R
R
R
u
d C
" to
J= iH
Q) P-i
i-i
p.
0 -H
O CD
R
R
NA
R
R
R
R
R
R
R
R
R
R
R
R
R
JUSTIFY ANY "NO" answer in an "R" box!
R = Recommended
0 = Optional
NA = Not Applicable
C-8
-------
Section
Spill Cleanup
Techniques
Cleanup /Disposal
Resources
Laboratory and
Consultant
Resources
Technical Library
or Bibliography
Plan Level:
Content
Description of Cleanup and
Containment Methods
Cleanup/Disposal Contractors
Cleanup Material and Equipment
Communications Equipment
Emergency Vehicles,
Cleanup Personnel
Personal Protective Equipment
Approved Disposal Sites
Colleges /Universities
Local Health Departments
Private/Industry Laboratories
Private Consultants
Government-Supported Labora-
tories or Research Institutes
List of Technical References
List of Maps
D
Is
££
0
0
R
R
R
0
R
0
0
R
0
0
0
0
0
n
°g
r-) rt
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a p*
R
R
R
R
R
R
R
R
R
R
R
R
R
0
0
Comprehen- i ,
sive Plan LJ
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
JUSTIFY ANY "NO" answer in an "R" box!
R = Recommended
0 = Optional
NA = Not Applicable
C-9
-------
Section
Hazards Analysis
Documentation of
Spill Events
Hazardous
Materials
Information
Training Exercises
Plan Level:
Content
Pollution Sources
Vulnerable Locations
Sensitive Environmental Areas
Initial Pollution Incident Report
Chronological Log
Final Pollution Incident Report
Spiller's Report
Investigative Report
Report Formats
Listing of Local Hazardous
Materials
Hazardous Material Definitions
Technical Information
Shipping Regulations
Training Criteria
D
0
i
H a
C n)
H r-l
S f^
R
R
R
0
0
0
0
0
0
0
0
0
0
0
n
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ri tfl
!§£
R
R
R
R
R
R
0
0
R
R
0
R
0
R
Comprehen-
sive Plan Q
R
R
R
R
R
R
R
R
R
R
R
R
R
R
JUSTIFY ANY "NO" answer in an "R" box!
R = Recommended
0 = Optional
NA = Not Applicable
C-10
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D. GENERAL PLAN QUALITY
1. Rank the plan by marking the scale as you think appropriate.
Scale:
Item No.
a
b
c
d
e
f
g
h
i
j
k
1
Item
V
1 ... 2 .
1 ... 2 .
1 ... 2 .
1 ... 2 .
1 . . . 2 . ,
1 . . . 2 . .
1 . . . 2 . .
1 . . . 2 . .
1 . . . 2 . .
1 . . . 2 . .
1 . . . 2 . .
1 . . . 2 . .
Identify any
Page No.
e.g., a mark here would mean "a
above average"
. . 3 Plain language; no excess vert
. . 3 Minimum jargon
. . 3 Technical terms def ined/unders
. . 3 Well written; readable
, . 3 Communicates its message
, . 3 Usable as intended
. 3 Consistent from section to sec
. 3 Well laid out and organized
. 3 Large type, dark print
. 3 Free of errors and typos
. 3 Any maps illustrations clear
. 3 Easy to find things
specific reason(s) for ranking below
Reason
little
>age
stood
ition
2.
Item
Page No.
Reason
Item
Page No.
Reason
C11
u-s- GOVERNMENT PRINTING OFFICE . 1982 0 - 37l)-798
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