NRT-1
Hazardous Materials Emergency
                Planning Guide
                         March 1987
        NATIONAL RESPONSE TEAM

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The  National  Response Team  (NRT)  — composed of 14 Federal  agencies
having major responsibilities in environmental, transportation, emergency man-
agement, worker safety, and public health areas — is the national body re-
sponsible for coordinating Federal planning, preparedness, and response ac-
tions related to oil discharges and hazardous substance releases.

NRT member agencies are:  Environmental Protection Agency (Chair), Depart-
ment of Transportation (U.S. Coast Guard) (Vice-chair), Department of Com-
merce, Department of the  Interior, Department of Agriculture, Department of
Defense, Department of State, Department of Justice, Department of Transpor-
tation (Research and Special Programs Administration), Department  of Health
and Human Services, Federal Emergency Management Agency, Department of
Energy, Department of Labor, and Nuclear Regulatory Commission.

Under the Superfund Amendments and Reauthorization Act of 1986, the NRT is
responsible for publishing guidance documents for the  preparation and imple-
mentation of hazardous substance emergency plans.

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

  United States
  Coast Guard

 Department of
   Commerce

 Department of
    Interior

 Department of
   Agriculture

 Department of
    Defense

 Department of
     State

 Department of
    Justice

 Department of
 Transportation

 Department of
   Health and
 Human Services

    Federal
   Emergency
  Management
    Agency

 Department of
    Energy

 Department of
     Labor
                                                   March 17, 1987
     The National Response Team (NRT)  Hazardous Materials
Emergency Planning Guide is a product  of the cooperative
efforts of the 14 Federal agencies that constitute the
NRT.  The guide fulfills a Congressional requirement that
the NRT provide unified Federal guidance for hazardous
materials emergency planning and presents a Federal con-
sensus upon which future guidance, technical assistance,
and training will be based.  It also reflects many comments
and suggestions received on earlier drafts from State and
local governments, industry representatives, emergency
managers, environmental organizations, and members of the
public actively concerned with hazardous materials prepared-
ness, response and prevention.

     This guide is an important step in a program of
implementation that will occur at Federal, State and local
levels of government throughout the United States.  Thank
you for your involvement in this important undertaking.   We
trus^i thisxTdocument will assist you in your efforts.
 .S. Environmental Protection Agency
Chairman
National Response Team
Capta,ir
U.S. Coast Guard
Vice-Chairman
National Response Team
          Report Oil and Chemical Spills Toll Free (8OO)424-88O2

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                                    NRT-1
   Hazardous  Materials Emergency
                      Planning Guide
                                  March 1987
             NATIONAL RESPONSE TEAM
(Replaces proposed Hazardous Materials Emergency Planning Guide dated November 1986)

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                         Table  of Contents
                                                                      PAGE

PREFACE 	 i

THE BACKGROUND OF THIS GUIDANCE	  ii

CHAPTER 1:  INTRODUCTION	  1

1.1  The Need for Hazardous Materials Emergency Planning 	  1

1.2  Purpose of This Guide 	  1

1.3  How to Use This Guide  	  2

1.4  Requirements for Planning	  4

    1.4.1  Federal Requirements	  4

    1.4.2  State and Local Requirements	  8

1.5  Related Programs and Materials	  8

    1.5.1  FEMA's Integrated Emergency Management System (CPG 1-8)  	  8

    1.5.2  EPA's Chemical Emergency Preparedness Program (CEPP)	  8

    1.5.3  DOT Materials  	  9

    1.5.4  Chemical Manufacturers Association's Community Awareness
          and Emergency Response Program (CMA/CAER) 	  9

CHAPTER 2:  SELECTING AND ORGANIZING THE  PLANNING TEAM	 11

2.1  Introduction	 11

2.2  The Planning Team	 11

    2.2.1  Forming the Planning Team	 11

    2.2.2  Respect for All Legitimate Interests  	 12

    2.2.3  Special  Importance of Local Governments	 14

    2.2.4  Local Industry Involvement	 14

    2.2.5  Size of Planning Team  	 14

2.3  Organizing the Planning Process	14

    2.3.1  Selecting a Team  Leader	 14

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                         Table of Contents (continued)
                                                                        PAGE
    2.3.2 Organizing for Planning Team Responsibilities	 16
2.4 Beginning to Plan  	 18
CHAPTER 3:   TASKS OF THE PLANNING TEAM	 19
3.1 Introduction	 19
3.2 Review of Existing Plans  	 19
3.3 Hazards Analysis:  Hazards Identification, Vulnerability Analysis, Risk Analysis .. 20
    3.3.1  Developing  the Hazards Analysis	21
    3.3.2 Obtaining Facility Information	24
    3.3.3 Example Hazards Analysis 	25
3.4 Capability Assessment	28
    3.4.1  Facility Resources	28
    3.4.2 Transporter Resources 	31
    3.4.3 Community Resources 	32
3.5 Writing an Emergency Plan	34
CHAPTER 4:   DEVELOPING THE PLAN 	35
4.1 Introduction	35
4.2 Hazardous Materials Appendix to Multi-Hazard EOP	35
4.3 Single-Hazard Emergency Plan	36
CHAPTER 5:   HAZARDOUS MATERIALS PLANNING ELEMENTS  	39
5.1 Introduction	39
5.2 Discussion of Planning  Elements  	40
CHAPTER 6:   PLAN APPRAISAL AND CONTINUING PLANNING  	 67
6.1 Introduction	67
6.2 Plan Review  and Approval	67
    6.2.1  Internal Review  	67
    6.2.2  External Review	 67

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                         Table  of Contents
(Continued)
                                                                     PAGE

    6.2.3  Plan Approval	68

6.3 Keeping the Plan Up-to-Date 	69

6.4 Continuing Planning 	 70

    6.4.1  Exercises 	70

    6.4.2  Incident Review 	71

    6.4.3  Training	71

APPENDICES

APPENDIX A:  IMPLEMENTING TITLE III: EMERGENCY PLANNING AND COMMUNITY
             RIGHT-TO-KNOW;  SUPERFUND AMENDMENTS AND REAUTHORIZATION
             ACT OF  1986

APPENDIX B:  LIST OF ACRONYMS AND RECOGNIZED ABBREVIATIONS

APPENDIX C:  GLOSSARY

APPENDIX D:  CRITERIA FOR ASSESSING STATE AND LOCAL PREPAREDNESS

APPENDIX E:  BIBLIOGRAPHY

APPENDIX F:  FEDERAL AGENCY ADDRESSES

EXHIBITS

Exhibit 1: Overview  of Planning  Process	3

Exhibit 2: Potential Members  of an Emergency Planning Team	 13

Exhibit 3: Example Hazards Analysis for a Hypothetical Community	 26

Exhibit 4: Sample Outline of a Hazardous Materials Emergency Plan	37

Exhibit 5: Key Title III Dates 	A-10

Exhibit 6: Title III — Major Information Flow/Requirements	A-11

Exhibit 7: Information from Facilities Provided by Title III in Support of LEPC
         Plan Development	A-12

Exhibit 8:  Title III Chemical Lists and Their Purposes  	A-13

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                                  Preface
All over America, large and small commu-
nities are learning about hazardous mate-
rials nearby.  Trains derail.  Trucks over-
turn.  Pipelines rupture.   Chemical plants
have accidental leaks  and releases.

This guidance will help local  communities
prepare for potential  incidents  involving
hazardous materials.  Some  communities
already  have  integrated   multi-hazard
plans;  other  communities are  only now
beginning  to  plan.    This guidance  de-
scribes how to form a local planning team,
find a  team leader, identify and analyze
hazards, identify existing  response equip-
ment and  personnel,  write  a plan, and
keep a plan up to date.

This guidance can be used both by local
communities  developing  their own plan,
and by local emergency planning commit-
tees formed  in accord  with  the  "Emer-
gency  Planning and  Community Right-to-
Know Act of 1986." This  legislation makes
it mandatory for local emergency planning
committees to prepare  an  emergency
plan for possible releases of hazardous
substances, and for fixed facilities to co-
operate in  this planning  process.  A de-
tailed summary of this legislation appears
in  Appendix  A;  the legislation  is refer-
enced  throughout this guide.

Information gathered during  the planning
process will help communities take steps
to make the impact of incidents less se-
vere.   Improved warning  systems,  in-
creased hazardous  materials training  of
industry and local  response personnel,
and other efforts at the local  level, can all
make  a community better  prepared  to
prevent and respond to hazardous materi-
als incidents.

Each  community must plan according to
its own situation:
    D   The  size  of  the  community
         (smaller  communities   might
         have fewer  hazards,  but also
         fewer planning and response re-
         sources for the hazards they do
         have);

    D   The level of danger (small com-
         munities  are  sometimes sur-
         rounded by large industry); and

    D   Preparedness   for    planning
         (some communities have active
         planning  agencies,   but  other
         communities   have  yet  to form
         their first planning committee).

There is  no  single right  way to write  a
plan.  This guidance presents a compre-
hensive  approach  to  planning.    Small
communities with few planning resources,
or communities with few or no threatening
hazards,  can  choose  the  planning ele-
ments appropriate to their circumstances.
Every community, however, should evalu-
ate  its preparedness for responding to  a
hazardous materials incident, and plan ac-
cordingly.

Fourteen  Federal agencies have cooper-
ated to produce this guidance.  We have
tried to make this guide consistent with
other guides you might  use during the
planning process. We  hope that this uni-
fied approach will help  your community.

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             The Background of This  Guidance
This Hazmat Emergency Planning  Guide
has been developed cooperatively  by  14
Federal agencies.  It is being published  by
the National  Response Team in compli-
ance  with Section 303(f) of the "Emer-
gency Planning and Community  Right-to-
Know Act of 1986," Title III of the "Super-
fund  Amendments and  Reauthorization
Act of 1986" (SARA).

This guide replaces the Federal Emer-
gency  Management  Agency's  (FEMA)
Planning Guide and Checklist for Hazard-
ous Materials Contingency  Plans  (popu-
larly known as FEMA-10).

This guide also incorporates material from
the U.S. Environmental Protection Agen-
cy's (EPA) interim guidance for its Chemi-
cal Emergency Preparedness  Program
(CEPP)  published late in 1985.  Included
are Chapters 2 ("Organizing the Commu-
nity"), 4 ("Contingency Plan Development
and Content"), and 5 ("Contingency Plan
Appraisal and Continuing Planning").  EPA
is  revising and updating CEPP  technical
guidance materials that will include site-
specific guidance,  criteria  for identifying
extremely hazardous  substances,  and
chemical profiles and a list of such sub-
stances.  Planners should  use  this gen-
eral planning guide in conjunction with the
CEPP  materials.

In  recent years, the U.S. Department  of
Transportation (DOT) has been  active  in
emergency planning.  The Research and
Special  Programs Administration (RSPA)
has published transportation-related re-
ports  and guides and  has  contributed  to
this general planning  guide.   The U.S.
Coast Guard  (USCG) has actively imple-
mented planning  and  response require-
ments of the  National Contingency Plan
(NCP), and has contributed to this general
planning guide.

The U.S. Occupational Safety and Health
Administration  (OSHA)  and the  U.S.
Agency for Toxic Substances and Disease
Registry (ATSDR) have assisted in prepar-
ing this general planning guide.

In  addition to its FEMA-10,  FEMA has de-
veloped and published a variety of plan-
ning-related materials.  Of special interest
here is Guide for Development of State and
Local Emergency Operations Plans (known
as CPG 1-8) that encourages communi-
ties to develop multi-hazard  emergency
operations plans (EOPs) covering all haz-
ards facing  a community (e.g., floods,
earthquakes, hurricanes, as well as haz-
ardous materials incidents). This general
planning guide complements CPG 1-8 and
indicates in Chapter 4 how hazardous ma-
terials  planners can develop or revise a
multi-hazard EOP.  Chapter  4 also de-
scribes a sample  outline for  an emer-
gency plan covering only hazardous mate-
rials,  if a community does not have the
resources to develop a multi-hazard EOP.

The  terms  "contingency plan,"  "emer-
gency plan," and "emergency operations
plan" are often used interchangeably, de-
pending upon whether one is reading the
NCP, CPG 1-8, or other planning guides.
This  guide consistently refers to "emer-
gency plans" and "emergency planning."

This  guide will consistently use "hazard-
ous materials" when generally  referring to
hazardous substances,   petroleum,  natu-
ral  gas," synthetic  gas, acutely   toxic
chemicals, and other toxic chemicals. Ti-
tle III of SARA uses the  term  "extremely
hazardous substances" to indicate those
chemicals that could  cause serious  irre-
versible health effects from accidental re-
leases.

The major differences between this docu-
ment and other versions proposed for re-
view are the  expansion  of the hazards
analysis discussion (Chapter 3) and the
addition of Appendix A explaining the plan-
ning provisions of Title III of SARA.
* We recognize that natural gas is under a
specific statute, but because this is a gen-
eral planning guide (and because criteria
for the list of  extremely hazardous sub-
stances under Title III of SARA may be ex-
panded to include flammability),  local
planners  may  want to consider natural
gas.

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                              1.  Introduction
 1.1  The Need for Hazardous Materials Emergency Planning
Major disasters like that in Bhopal,  India,
in  December  1984,  which  resulted  in
2,000 deaths and over  200,000  injuries,
are rare.  Reports of hazardous materials
spills and releases, however, are  increas-
ingly commonplace.   Thousands of new
chemicals are developed each year.  Citi-
zens and  officials  are concerned about
accidents  (e.g., highway incidents, ware-
house fires, train derailments, industrial
incidents)  happening  in their  communi-
ties. Recent evidence shows that hazard-
ous materials incidents are considered by
many to be the most significant threat fac-
ing local jurisdictions.  Ninety-three per-
cent of the more than 3,100 localities
completing the Federal Emergency Man-
agement Agency's (FEMA) Hazard Identi-
fication,   Capability   Assessment,   and
Multi-Year Development Plan during fiscal
year 1985 identified one or more hazard-
ous materials risks (e.g., on highways and
railroads, at fixed facilities) as a significant
threat to the community.   Communities
need  to  prepare themselves  to  prevent
such incidents and to respond to the acci-
dents that do occur.

Because  of the  risk of hazardous materi-
als  incidents and because  local  govern-
ments will be completely on their own in
the first stages  of almost any hazardous
materials incident,  communities need  to
maintain  a continuing preparedness ca-
pacity. A specific, tangible result of being
prepared is  an  emergency plan.   Some
communities  might  have  sophisticated
and detailed written plans but,  if the plans
have  not  recently  been tested  and  re-
vised, these communities  might  be less
prepared than they think for  a possible
hazardous materials incident.
                       1.2   Purpose of This  Guide
The purpose of this guide is to assist com-
munities in planning for hazardous materi-
als incidents.

"Communities" refers primarily to local ju-
risdictions.  There  are other groups of
people, however, that  can profitably  use
this guide.  Rural  areas  with limited re-
sources may need to plan at the county or
Regional level.  State officials seeking to
develop a State emergency plan  that is
closely coordinated with  local plans  can
adapt  this guidance to their purposes.
Likewise, officials of chemical plants,  rail-
road yards, and shipping  and trucking
companies can  use this guidance to coor-
dinate  their  own  hazardous  materials
emergency planning with that of the local
community.

"Hazardous materials" refers generally to
hazardous substances, petroleum, natural
gas, synthetic gas, acutely toxic  chemi-
cals, and other toxic chemicals.   "Ex-
tremely hazardous substances" is used in
Title III of the Superfund Amendments and
Reauthorization  Act of  1986 to refer  to
those chemicals that could cause serious
health effects following short-term expo-
sure from accidental releases.  The U.S.
Environmental  Protection  Agency  (EPA)
published  an  initial list  of 402  extremely
                                     Page 1

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hazardous substances  for  which emer-
gency planning is required.  Because this
list may be revised, planners should con-
tact EPA Regional offices to  obtain infor-
mation.  This guidance deals specifically
with response to hazardous materials inci-
dents—both  at fixed  facilities (manufac-
turing, processing, storage, and disposal)
and during transportation (highways, wa-
terways,  rail, and air).  Plans for respond-
ing to radiological incidents  and natural
emergencies such as hurricanes, floods,
and earthquakes are not the focus of this
guidance, although most aspects of  plan
development and appraisal are common
to  these emergencies.   Communities
should  see  NUREG  0654/FEMA-REP-1
and/or FEMA-REP-5  for assistance in ra-
diological planning.   (See Appendix C.)
Communities should  be prepared,  how-
ever, for the possibility that natural emer-
gencies,  radiological  incidents, and haz-
ardous materials incidents will cause or
reinforce each other.

The objectives of this guide are to:
     D   Focus  community  activity  on
         emergency   preparedness  and
         response;
     D   Provide  communities with infor-
         mation useful  in organizing the
         planning task;
     D   Furnish criteria to determine risk
         and to help communities  decide
         whether they need to  plan  for
         hazardous materials incidents;
     D   Help communities conduct plan-
         ning that is consistent with their
         needs and capabilities;  and
     D   Provide a method for continually
         updating  a community's  emer-
         gency plan.

This guide will not:
     D   Give  a   simple   "fill-in-the-
         blanks"  model  plan  (because
         each  community   needs   an
         emergency plan suited to its own
         unique circumstances);
     D   Provide   details  on  response
         techniques; or
     D   Train personnel to respond to in-
         cidents.

Community planners will need to consult
other resources in addition to this  guide.
Related programs  and materials are dis-
cussed in Section  1.5.
                        1.3  How to Use This  Guide
This guide has been designed so it can be
used  easily by both  those  communities
with little or no planning experience and
those communities with extensive  plan-
ning experience.

All  planners should consult  the decision
tree in Exhibit 1 for assistance in using this
guide.

Chapter  2 describes  how  communities
can organize a planning team.  Communi-
ties  that are  beginning  the emergency
planning  process  for  the first time will
need  to follow Chapter 2 very  closely in
order to organize their efforts effectively.
Communities  with  an   active   planning
agency might briefly review Chapter 2, es-
pecially to be sure that all of the proper
people are included in the planning proc-
ess, and  move on to Chapter 3 for a de-
tailed discussion  of tasks for  hazardous
materials planning.   Planners should re-
view existing emergency plans, perform a
hazards identification and analysis, assess
prevention and response capabilities, and
then write or revise  an emergency plan.
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                                            Exhibit 1
                         OVERVIEW OF  PLANNING PROCESS
                                         Determine that a
                                          Plan is Needed
                                       Select Planning Team
                                    Members and Team Leader
                                          (See Chapter 2)
                                           Begin to Plan
Review and Coordinate with
      Existing Plans
     (See Chapter 3)
Assess Response
  Capabilities
                Conduct Hazards
            Identification and Analysis
                 (See Chapter 3)
                      Assess Industry
                    Response Capabilities
                      (See Chapter 3)
                   Assess Community
                  Response Capabilities
                    (See Chapter 3)
                                            Write Plan
                                       (See Chapters 4 and 5)
                 Develop or Revise Multi-
                   Hazard Emergency
                     Operations Plan
                     (See Chapter 4)
       or
 Develop or Revise
Hazardous Materials
  Emergency Plan
  (See Chapter 4)
                                        Seek Plan Approval
                                         Revise, Test, and
                                           Maintain Plan
                                          (See Chapter 6)
                                              Page 3

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Chapter  4  discusses  two  basic  ap-
proaches to writing an emergency plan:
(a)  incorporating   hazardous   materials
planning  into a multi-hazard emergency
operations   plan   (EOF)   (see  Section
1.5.1); and  (b) developing or  revising  a
plan dealing only  with hazardous materi-
als.  Incorporating  hazardous   materials
planning  into a multi-hazard approach  is
preferable. Some communities, however,
have  neither the capability  nor the re-
sources to do this immediately.  Commu-
nities that choose to develop or revise an
EOF should  consult FEMA's CFG 1-8 for
specific  structure  requirements for  the
plan in addition to the discussion in Sec-
tion 1.5.1.   Communities that  choose to
develop or revise a single-hazard plan for
hazardous materials can use the sample
outline of an emergency plan in Chapter 4
to organize the various hazardous materi-
als planning  elements.  (Note:   Communi-
ties receiving FEMA funds must incorpo-
rate hazardous materials planning  into  a
multi-hazard EOF.)

Chapter 5 describes the elements  to be
considered  when  planning for potential
hazardous materials incidents.   All com-
munities (both those preparing an EOF un-
der the multi-hazard approach  and  those
preparing  a single-hazard  plan)  should
carefully  follow Chapter 5  to ensure that
they consider and  include the planning
elements related to hazardous  materials.
Chapter 6 describes how to  review and
update a  plan.   Experience  shows that
many communities mistakenly  presume
that completing an emergency plan auto-
matically ensures  adequate preparedness
for emergency response.  All communi-
ties should follow the recommendations in
Chapter 6 to ensure that emergency plans
will be helpful during a  real incident.

Appendix A  is a summary for implement-
ing the  "Emergency Planning and  Com-
munity Right-to-Know Act  of 1986." Ap-
pendix B is a list of acronyms and abbre-
viations used in this guidance.  Appendix
C is a glossary of terms used throughout
this guide.   (Because this guide neces-
sarily contains many acronyms and tech-
nical  phrases,  local  planners should
regularly consult  Appendices B and C.)
Appendix D contains criteria for assessing
State  and local preparedness.  Planners
should use this appendix as a checklist to
evaluate their  hazards analysis,  the  legal
authority for  responding, the response or-
ganizational   structure,  communication
systems, resources, and  the completed
emergency plan.  Appendix E is a  list of
references on various topics addressed in
this guidance.   Appendix F is a listing of
addresses of Federal agencies at the na-
tional  and   Regional  levels.    Planners
should contact the  appropriate  office for
assistance in the planning  process.
                    1.4  Requirements  for Planning
Planners   should   understand  Federal,
State, and local requirements that apply
to emergency planning.

1.4.1  Federal Requirements
This section discusses the principal  Fed-
eral planning requirements found in the
National  Contingency Plan;   Title  III  of
SARA; the Resource Conservation and Re-
covery Act; and FEMA's  requirements for
Emergency Operations Plans.
^- A.  National Contingency Plan

The National Contingency Plan (NCP), re-
quired by section  105 of the Comprehen-
sive Environmental Response, Compensa-
tion,  and Liability Act (CERCLA), calls for
extensive  preparedness  and  planning.
The National Response Team (NRT), com-
prised of representatives of various  Fed-
eral government agencies with major envi-
ronmental,   transportation,   emergency
management,  worker  safety,  and public
health responsibilities, is responsible for
                                     Page 4

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coordinating Federal emergency prepar-
edness and planning on a nationwide ba-
sis.

A key element of Federal support to local
responders  during  hazardous  materials
transportation and fixed facility incidents is
a response by U.S. Coast Guard (USCG)
or Environmental Protection Agency (EPA)
On-Scene  Coordinators   (OSCs).    The
OSC is the Federal official predesignated
to  coordinate  and  direct  Federal re-
sponses and removals under the  NCP.
These  OSCs are  assisted  by Federal Re-
gional  Response  Teams  (RRTs) that are
available to provide advice and support to
the OSC and,  through  the OSC, to local
responders.

Federal responses may be triggered by a
report  to the  National  Response  Center
(NRC),  operated by  the Coast  Guard.
Provisions of the Federal  Water Pollution
Control Act (Clean  Water Act), CERCLA
("Superfund"),  and various other Federal
laws require persons responsible for a dis-
charge or release to notify the NRC imme-
diately.  The NRC Duty Officer promptly
relays  each  report  to the  appropriate
Coast Guard or EPA OSC, depending on
the location of an incident.  Based on this
initial report and any other information that
can be obtained, the OSC makes a pre-
liminary assessment of the need  for  a
Federal response.

This activity may  or may not  require the
OSC or his/her representative to go to the
scene of an incident.  If an on-scene re-
sponse is required, the OSC will go to the
scene and monitor the response of the re-
sponsible party or State or local govern-
ment.  If the responsible party is unknown
or not taking appropriate action, or the re-
sponse is beyond the  capability of State
and local governments, the OSC may initi-
ate Federal actions. The Coast Guard has
OSCs at 48 locations  (zones)  in  10 dis-
tricts, and the EPA has OSCs in its 10 Re-
gional offices and in certain EPA field of-
fices.    (See Appendix F for  appropriate
addresses.)

Regional Response Teams are  composed
of representatives from Federal agencies
and  a  representative  from each State
within a Federal  Region.   During a re-
sponse  to a major hazardous materials in-
cident involving transportation  or  a fixed
facility, the OSC may request that the RRT
be convened to provide advice or  recom-
mendations on specific issues requiring
resolution.

An  enhanced  RRT role in  preparedness
activities  includes assistance  for  local
community planning efforts. Local emer-
gency plans should be coordinated with
any  Federal Regional contingency plans
and  OSC  contingency  plans prepared in
compliance with the NCP.  Appendix D of
this guide contains an adaptation of exten-
sive criteria developed by the NRT  Prepar-
edness Committee to assess State and/or
local emergency response  preparedness
programs.  These criteria should be used
in conjunction with Chapters 3,4, and 5 of
this guide.

^ 8. Title  III  of   SARA   ("Superfund
      Amendments  and  Reauthorization
      Act of 1986")

Significant new hazardous materials emer-
gency  planning  requirements  are  con-
tained in Title III of SARA (also known  as
the  "Emergency Planning and Community
Right-to-Know Act of 1986").   (See Ap-
pendix A for a detailed summary on imple-
menting Title III.)

Title III of SARA requires the  establishment
of  State emergency response commis-
sions, emergency planning  districts, and
local  emergency  planning  committees.
The  Governor  of  each State appoints a
State emergency response commission
whose responsibilities include:  designat-
ing emergency planning districts; appoint-
ing local emergency planning committees
for each district; supervising and  coordi-
nating the  activities of  planning commit-
tees;  reviewing emergency  plans;  receiv-
ing chemical release notifications;  and es-
tablishing  procedures for  receiving and
processing requests  from the public for
information about  and/or copies of emer-
gency  response  plans, material   safety
data sheets, the list of  extremely  hazard-
ous substances prepared as part of EPA's
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original Chemical  Emergency  Prepared-
ness   Program  initiative  (see  Section
1.5.2), inventory forms,  and toxic chemi-
cal release forms.

Forming emergency planning  districts is
intended to facilitate the preparation and
implementation  of  emergency  plans.
Planning districts may be existing political
subdivisions or multijurisdictional planning
organizations. The local  emergency plan-
ning committee  for each district must in-
clude  representatives from each of  the
following groups or organizations:

    D   Elected State and local officials;
    D   Law enforcement, civil defense,
         firefighting, health, local environ-
         mental, hospital, and transporta-
         tion personnel;
    D   Broadcast and print media;
    D   Community groups; and
    D   Owners and  operators of facili-
         ties subject to  the requirements
         of Title III  of SARA.

Each emergency planning committee is to
establish procedures  for  receiving  and
processing  requests from  the  public  for
information about and/or copies of emer-
gency  response plans,  material safety
data  sheets,   and  chemical  inventory
forms. The committee must designate an
official to serve as  coordinator of informa-
tion.

Facilities are subject to  emergency plan-
ning and  notification  requirements if a
substance on EPA's list of extremely haz-
ardous substances is present at the facil-
ity in an amount in excess of the threshold
planning • quantity  for  that  substance.
(See Federal Register,  Vol. 51,  No. 221,
41570  ef seq.)  The owner  or operator of
each facility subject to these requirements
must  notify the  appropriate State emer-
gency response commission that the facil-
ity is subject to the requirements.

Each facility must also notify the appropri-
ate emergency  planning committee of a
facility representative who will  participate
in  the  emergency  planning process as a
facility emergency  coordinator.   Upon  re-
quest, facility owners and operators are to
provide the appropriate emergency plan-
ning committee with  information  neces-
sary for developing and implementing the
emergency plan for the planning district.

Title III provisions help to ensure that ade-
quate information is available for the plan-
ning committee to know which facilities to
cover in the plan.  (See Appendix A for a
discussion  of how the local planning com-
mittee can use information generated  by
Title III.) Section 303 (d) (3) requires facil-
ity owners and operators to provide to the
local   emergency  planning   committee
whatever information is necessary  for de-
veloping and implementing the  plan.

When there is  a release  of a chemical
identified by Title  III of SARA, a  facility
owner or operator, or a transporter of the
chemical,   must  notify the  community
emergency  coordinator  for  the  emer-
gency planning  committee for each area
likely to be  affected by the release,  and
the State emergency response commis-
sion of any State likely to  be affected by
the release.   (This Title  III requirement
does not replace the legal  requirement to
notify the   National Response  Center for
releases of CERCLA Section 103 hazard-
ous substances.)

Each emergency planning committee is to
prepare an  emergency  plan  by October
1988 and review it annually.  The commit-
tee also evaluates the need for  resources
to develop,  implement,  and exercise  the
emergency plan; and  makes recommen-
dations with respect to additional needed
resources and how to provide them. Each
emergency  plan  must  include: facilities
and transportation  routes  related to spe-
cific chemicals;  response procedures of
facilities, and local emergency and medi-
cal personnel; the names  of community
and facility emergency coordinators;  pro-
cedures for notifying officials and the pub-
lic in the event of a release; methods for
detecting a release and identifying areas
and  populations  at  risk; a description of
emergency equipment and facilities in the
community and at specified fixed facilities;
evacuation  plans; training  programs;  and
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schedules for exercising the emergency
plan. (These plan requirements are listed
in greater detail in Chapter 5.) The com-
pleted plan is to be  reviewed by the State
emergency response commission and, at
the request of the local emergency plan-
ning committee,  may be reviewed by the
Federal  Regional Response Team.

(Note:  Many  local  jurisdictions  already
have emergency  plans  for various types
of hazards. These plans may only require
modification to meet emergency plan re-
quirements in Title III of  SARA.)

Finally, with regard to planning, Title III of
SARA requires the  NRT to  publish guid-
ance for the preparation and  implementa-
tion of emergency plans. This Hazardous
Materials Emergency Planning Guide is in-
tended to fulfill this requirement.  Other
Title III provisions supporting  emergency
planning  are discussed  in Appendix A.

^ C. Resource Conservation and Recov-
      ery Act

The Resource Conservation and Recovery
Act  (RCRA)  established a framework for
the proper management and disposal of
all wastes.   The Hazardous  and Solid
Waste Amendments of  1984 (HSWA)  ex-
panded  the scope of the law and placed
increased emphasis on  waste  reduction,
corrective action, and treatment  of haz-
ardous wastes.

Under Subtitle C of  RCRA, EPA identifies
hazardous wastes,  both generically  and
by listing  specific wastes and industrial
process waste  streams; develops stan-
dards and regulations for proper manage-
ment of hazardous wastes by the genera-
tor and transporter, which include a mani-
fest  that accompanies  waste shipments;
and develops standards for the treatment,
storage,  and  disposal  of  the  wastes.
These  standards  are   generally  imple-
mented  through permits which  are issued
by EPA or an authorized State.  To receive
a permit, persons wishing to treat, store,
or dispose of hazardous wastes  are re-
quired  to  submit  permit   applications,
which must include  a characterization of
the hazardous wastes to  be handled at the
facility, demonstration of compliance with
standards and  regulations  that apply to
the  facility,  and  a  contingency  plan.
There are required opportunities for public
comment on the draft permits,  through
which local  governments and  the  public
may comment on  the  facility's  contin-
gency  plan.   It  is  important  that local
emergency response authorities be famil-
iar with contingency plans of these facili-
ties.  Coordination  with local community
emergency response agencies  is required
by regulation (40 CFR 264.37), and EPA
strongly  encourages  active  community
coordination of local response capabilities
with facility plans.

When a community is preparing an emer-
gency  plan that includes  underground
storage tanks (containing either wastes or
products), it should coordinate  with EPA's
Regional  offices,  the States,  and local
governments. Underground  storage tanks
are regulated  under Subtitle  C  or I  of
RCRA.

^- D. FEMA Emergency Operations Plan
      Requirements

Planning requirements for jurisdictions re-
ceiving FEMA funds are set forth in 44 CFR
Part  302, effective May 12, 1986.  This
regulation calls  for States and  local gov-
ernments to prepare an emergency  op-
erations plan (EOP)  which conforms with
the requirements for plan  content con-
tained in FEMA's CPG 1-3, CPG 1-8, and
CPG 1-8A.  These State and local govern-
ment EOPs  must identify the available per-
sonnel,  equipment,  facilities,  supplies,
and  other  resources  in the jurisdiction,
and state the method or scheme for coor-
dinated actions  to be taken  by  individuals
and government services in the event of
natural, man-made (e.g., hazardous ma-
terials), and attack-related disasters.

^- £. OS HA Regulations

Occupational Safety  and  Health  Admini-
stration regulations require employers in-
volved in hazardous waste  operations to
develop and implement an emergency re-
sponse plan  for  employees.  The ele-
ments of  this plan must include: (1) rec-
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ognition of emergencies;  (2) methods or
procedures  for  alerting  employees  on
site;  (3)   evacuation  procedures  and
routes to  places  of  refuge or safe dis-
tances away from the  danger area;  (4)
means and methods for emergency medi-
cal treatment and first aid for employees;
(5) the  line of authority  for employees;
(6) on-site decontamination procedures;
(7) site control means; and (8)  methods
for evaluating the plan.  Employers whose
employees will be responding to hazard-
ous materials emergency incidents from
their regular work location or duty station
(e.g., a fire department,  fire brigade, or
emergency  medical  service)  must also
have an emergency response plan.  (See
29 CFR Part 1910.120.)

1.4.2  State and Local Requirements
Many States have adopted individual laws
and regulations that address local govern-
ment involvement in hazardous materials.
Local authorities should investigate  State
requirements and programs before they
initiate preparedness  and planning activi-
ties.   Emergency plans  should include
consideration of any  State or local  com-
munity right-to-know laws.  When these
laws are more demanding than  the Fed-
eral law, the State and local laws some-
times take  precedence over the Federal
law.
                1.5  Related Programs and Materials
Because emergency  planning is  a  com-
plex process involving a variety of issues
and   concerns,  community   planners
should consult related public and private
sector programs and materials.  The fol-
lowing are selected examples of planning
programs and materials that may be used
in conjunction with this guide.

1.5.1   FEMA's   Integrated  Emergency
       Management System (CPG 1-8)
FEMA's Guide for Development of State
and  Local  Emergency  Operations  Plans
(CPG  1-8) provides information for emer-
gency  management   planners  and  for
State  and local government officials about
FEMA's concept of emergency operations
planning under the Integrated Emergency
Management System (IEMS).  IEMS em-
phasizes the integration  of planning  to
provide for all  hazards discovered in a
community's hazards  identification  proc-
ess.  CPG 1-8 provides  extensive guid-
ance  in  the coordination, development,
review,  validation, and revision of  EOPs
(see  Section 4.2).   (See page  F-1  for
FEMA's address and telephone number.)

This guide for hazardous materials emer-
gency planning is deliberately  meant  to
complement CPG 1-8.   Chapter 4 de-
scribes how a community can incorporate
hazardous materials planning into an exist-
ing  multi-hazard  EOP, or how it can de-
velop a  multi-hazard  EOP while address-
ing  possible  hazardous  materials inci-
dents.   In  either  case,  communities
should obtain a  copy of CPG  1-8 from
FEMA and follow its  guidance  carefully.
All communities,  even those with sophisti-
cated multi-hazard EOPs, should consult
Chapter 5 of this guide to ensure ade-
quate consideration of hazardous materi-
als  issues.

1.5.2 EPA's Chemical Emergency Pre-
      paredness Program (CEPP)
In June  1985, EPA announced a compre-
hensive  strategy  to deal with planning for
the problem of toxics released to the air.
One section of this strategy, the Chemical
Emergency    Preparedness    Program
(CEPP), was designed to  address acci-
dental releases  of acutely  toxic chemi-
cals.  This program has two goals: to in-
crease community awareness of chemical
hazards and to  enhance State  and local
emergency  planning  for   dealing with
chemical accidents.  Many of the CEPP
goals and objectives are included in Title III
of  SARA  (see  Section  1.4.1).    EPA's
CEPP materials (including technical  guid-
ance, criteria  for identifying extremely
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hazardous substances, chemical profiles
and list) are designed to complement this
guidance and  to  help  communities per-
form hazards identification and analysis as
described in Chapter  3 of this  guide.
CEPP materials can be obtained by writing
EPA.  (See page  F-1.)

1.5.3 DOT Materials
The U.S. Department of Transportation's
(DOT) Community Teamwork is a guide to
help  local communities  develop a  cost-
effective hazardous materials transporta-
tion safety program.  It discusses hazards
assessment  and risk analysis, the devel-
opment of an  emergency  plan, enforce-
ment,  training, and legal  authority for
planning.    Communities   preparing  an
emergency plan for transportation-related
hazards might use Community Teamwork
in conjunction with this  guide.

Lessons Learned is a  report on seven haz-
ardous materials safety  planning projects
funded by DOT. The projects included lo-
cal plans for Memphis, Indianapolis, New
Orleans,  and Niagara County  (NY);  Re-
gional plans for Puget Sound and the Oak-
land/San Francisco Bay Area; and a State
plan  for Massachusetts.   The Lessons
Learned report synthesizes the actual ex-
periences of these  projects during  each
phase of the planning process.  A major
conclusion of this  study was that local po-
litical leadership and support from  both
the executive and legislative branches are
important factors  throughout the planning
process. Chapter 2 of this guide incorpo-
rates portions of the experiences and con-
clusions from Lessons Learned.

DOT's Emergency Response Guidebook
provides guidance for firefighters,  police,
and other emergency services personnel
to help them protect themselves and the
public during the  initial  minutes immedi-
ately following a hazardous materials inci-
dent.   This widely  used  guidebook is
keyed  to the  identification placards re-
quired by DOT  regulations to be displayed
prominently on vehicles  transporting haz-
ardous  materials.    All  first responders
should have copies of the Emergency Re-
sponse Guidebook and know how to use it.
DOT has  also  published a  four-volume
guide for small towns and rural areas writ-
ing  a  hazardous  materials emergency
plan.  DOT's objectives were to alert offi-
cials of those communities to the threat to
life, property, and the  environment from
the  transportation of hazardous materials,
and  to  provide simplified  guidance  for
those with little  or no technical expertise.
Titles of the volumes are:   Volume I, A
Community Model for Handling Hazardous
Materials  Transportation  Emergencies;
Volume II, Risk  Assessment Users Manual
for  Small Communities  and  Rural Areas;
Volume III, Risk Assessment/Vulnerability
Model Validation; and, Volume IV, Manual
for  Small Towns and Rural  Areas to De-
velop a Hazardous  Materials Emergency
Plan.   (See Page F-1 for DOT's  address
and telephone number.)

1.5.4  Chemical Manufacturers Associa-
       tion's Community Awareness and
       Emergency  Response   Program
       (CMA/CAER)
The  Chemical   Manufacturers  Associa-
tion's (CMA)  Community Awareness and
Emergency Response  (CAER)  program
encourages chemical plant managers to
take the initiative in cooperating with local
communities to develop integrated emer-
gency  plans for responding to hazardous
materials incidents.  Because chemical in-
dustry  representatives  can  be especially
knowledgeable  during the planning  proc-
ess, and because many chemical  plant of-
ficials are willing and able to share equip-
ment and personnel  during response op-
erations,  community planners should seek
out  local CMA/CAER participants. Even if
no such local initiative is in place,  commu-
nity planners can approach chemical plant
managers or contact CMA and ask for as-
sistance  in the  spirit of the CAER pro-
gram.

Users of this general planning guide  might
also purchase and use the following three
CMA/CAER   publications:   "Community
Awareness and  Emergency  Response
Program  Handbook,"  "Site Emergency
Response Planning,"  and   "Community
Emergency Response Exercise Program."
(See Appendix  E for CMA's address.)
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   2.  Selecting  and Organizing the Planning Team
                             2.1  Introduction
This chapter discusses the selection and
organization of  the team members who
will coordinate hazardous materials plan-
ning.  The guidance stresses  that suc-
cessful  planning requires community  in-
volvement throughout the process. Enlist-
ing the  cooperation of all parties directly
concerned  with hazardous materials will
improve  planning, make  the plan more
likely to be used, and maximize the likeli-
hood of an effective response at the time
of an emergency.  Experience shows that
plans are not used if they are  prepared
by only one  person or  one agency.
Emergency response requires trust, co-
ordination, and cooperation among re-
sponders who need to know who is re-
sponsible for what activities, and who is
capable of performing  what activities.
This knowledge  is gained only through
personal interaction.  Working together
in developing and updating plans is  a
major opportunity for cooperative inter-
action among responders.
(As indicated in Section 1.4.1, Title III of
SARA requires  Governors  to  appoint a
State emergency  response commission
that  will  designate emergency planning
districts  and appoint  local  emergency
planning  committees for  each  district.
The  State commission  might  follow the
guidance in this chapter when appointing
planning committees.)
                        2.2  The Planning Team
Hazardous materials planning should grow
out of a process coordinated by a team.
The team is the best vehicle for incorpo-
rating the expertise of a variety of sources
into the planning process and for produc-
ing an accurate and complete document.
The  team approach also encourages a
planning process that reflects the consen-
sus of the entire community.  Some indi-
vidual communities and/or areas that in-
clude several communities have formed
hazardous  materials  advisory   councils
(HMACs).   HMACs, where they  exist, are
an  excellent  resource for the  planning
team.
2.2.1  Forming the Planning Team
In selecting the members of a team that
will bear overall responsibility for hazard-
ous materials planning, four considera-
tions are most important:
    D   The members of the group must
        have the ability, commitment,
        authority, and resources to get
        the job done;

    D   The  group   must  possess,  or
        have ready  access to, a wide
        range of expertise  relating  to
        the community, its industrial fa-
        cilities  and  transportation  sys-
        tems, and   the  mechanics  of
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         emergency  response  and  re-
         sponse planning;

     D   The members of the group must
         agree on their purpose and be
         able to work cooperatively with
         one another; and

     D   The group must be representa-
         tive of all elements of the com-
         munity with a substantial interest
         in  reducing the risks  posed by
         hazardous materials.
A  comprehensive  list  of  potential team
members is presented in Exhibit 2.

In  those  communities receiving  FEMA
funds, paid staff may already be in place
for emergency operations planning  and
other  emergency  management tasks.
This  staff  should be  an obvious resource
for hazardous materials planning.  FEMA
has  two training courses  for the person
assigned as the planning team leader and
for team  members  —   Introduction to
Emergency Management, and Emergency
Planning. Another course,  Hazardous  Ma-
terials Contingency Planning,  is an inter-
agency "train-the-trainer"  course   pre-
sented cooperatively by EPA, FEMA,  and
other NRT agencies.  Course  materials
and the schedule of offerings are available
through State emergency management
agencies.

2.2.2  Respect for  All Legitimate Inter-
       ests
While many individuals have a  common in-
terest in reducing the risks posed by haz-
ardous  materials,   their  differing  eco-
nomic, political,  and social  perspectives
may cause them to favor different means
of  promoting safety.  For example, people
who  live near a facility with hazardous  ma-
terials are likely to be  greatly concerned
about  avoiding any  threat to their lives,
and  are likely to be less intensely con-
cerned about the costs of developing ac-
cident prevention and response measures
than some of the other groups involved.
Others in  the  community are likely to be
more sensitive to the costs involved, and
may be anxious to avoid expenditures for
unnecessarily  elaborate  prevention  and
response measures.  Also, facility manag-
ers may be reluctant for proprietary rea-
sons to disclose materials and processes
beyond what is required by law.

There may also be differing views among
the agencies and organizations with emer-
gency response functions about the roles
they should play  in case of an incident.
The local  fire  department, police depart-
ment,  emergency management  agency,
and public health agency are all likely to
have some  responsibilities in responding
to an incident.  However, each of these
organizations might envision a very differ-
ent set of responsibilities for their respec-
tive agencies for planning or for manage-
ment on scene.

In organizing the community to  address
the problems  associated with  hazardous
materials, it is important to bear in mind
that all affected parties have a legitimate
interest in the choices  among planning
alternatives.   Therefore,  strong efforts
should  be made to ensure that all groups
with an interest  in the planning  process
are included.

Some interest groups in the community
have well-defined political identities  and
representation, but others may not.  Gov-
ernment agencies, private industry, envi-
ronmental groups, and trade unions at the
facilities are all likely to have ready institu-
tional  access  to an  emergency  planning
process.   Nearby  residents, however,
may lack  an effective vehicle  for institu-
tional  representation.  Organizations that
may be available to represent the resi-
dents'  interests include neighborhood as-
sociations, church organizations, and ad
hoc organizations  formed  especially to
deal with the risks posed by the presence
of specific hazardous materials in a  neigh-
borhood.
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                                    Exhibit 2
        POTENTIAL MEMBERS  OF AN EMERGENCY PLANNING TEAM
Part A:     Experience shows that the following individuals,  groups, and agencies
           should participate in order for a successful plan to be developed:
          'Mayor/city manager (or representative)
          "County executive (or representative)/board of supervisors
          *State elected officials  (or representative)
          *Fire department (paid  and volunteer)
          *Police department
          "Emergency management or civil defense agency
          "Environmental agency  (e.g., air and/or water pollution control agency)
          "Health department
          "Hospitals, emergency medical service,  veterinarians, medical community
          "Transportation agency  (e.g., DOT, port authority, transit authority, bus company,
           truck or rail companies)
          "Industry (e.g., chemical and transportation)
           Coast Guard/EPA representative  (e.g., agency response program personnel)
           Technical experts (e.g., chemist, engineer)
          "Community group representative
          "Public  information representative (e.g., local radio, TV, press)
Part B:     Other groups/agencies that can be included in the planning process,
           depending on the community's individual priorities:
           Agriculture agency
           Indian tribes within or adjacent to the affected jurisdiction
           Public works (e.g.,  waste disposal, water, sanitation, and roads)
           Planning department
           Other agencies (e.g., welfare, parks, and utilities)
           Municipal/county legal counsel
           Workers in local facilities
           Labor union representatives  (e.g., chemical and transportation, industrial
           health  units)
           Local business community
           Representatives from volunteer organizations (e.g., Red  Cross)
           Public  interest and citizens groups, environmental  organizations, and
           representatives of affected neighborhoods
           Schools or school districts
           Key representatives from bordering cities and counties
           State representatives (Governor, legislator's office, State agencies)
           Federal agency representatives (e.g., FEMA,  DOT/RSPA, ATSDR, OSHA)

"Required by Title III of SARA
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2.2.3  Special Importance of Local Gov-
       ernments
For several reasons,  local governments
have a critical role to play in  the  devel-
opment  of  emergency  preparedness.
First,  local governments bear major  re-
sponsibilities  for protecting public  health
and safety; local police and fire depart-
ments, for example, often  have the lead
responsibility for the initial response to in-
cidents  involving  hazardous  materials.
Second,  one  of the functions of local gov-
ernment  is to mediate and resolve the
sometimes competing ideas of different
interest groups.  Third, local governments
have the resources to gather  necessary
planning  data. Finally, local governments
generally have the legislative authority to
raise funds for equipment and personnel
required  for emergency response.   Sup-
port  from  the  executive and  legislative
branches is essential  to successful plan-
ning.   Appropriate government leaders
must give adequate authority to those re-
sponsible for emergency planning.

2.2.4   Local  Industry  Involvement
Because  fixed facility  owners and opera-
tors  are  concerned about public  health
and safety in the event of  an  accidental
release of a  hazardous material, and be-
cause  many facility employees  have tech-
nical expertise that  will be  helpful  to the
planning  team,  the team  should include
one or more facility representatives. Title
III of SARA requires facility owners or op-
erators to notify the emergency planning
committee of a facility representative who
will participate in the emergency planning
process as a facility emergency coordina-
tor. In planning districts that include sev-
eral fixed facilities, one or more represen-
tative  facility   emergency  coordinators
could be active members of the planning
team.  The  planning team could consult
with the other facility emergency coordi-
nators and/or assign them to task forces
or committees (see Section  2.3.2). Title
III of SARA also requires facilities to submit
to the local emergency planning commit-
tee any information needed to develop the
plan.

2.2.5  Size of  Planning Team
For the  planning team to function effec-
tively, its size should be limited to a work-
able number.  In communities with many
interested  parties,  it will be necessary to
select from among them carefully so as to
ensure fair and comprehensive  represen-
tation.  Some individuals may feel left out
of the planning process. This can be off-
set by providing these individuals access
to the process through the  various ap-
proaches noted in  the following sections,
such as membership on a task force or
advisory council.    In addition,  all inter-
ested parties should have  an opportunity
for input during the review process.
                2.3  Organizing the Planning Process
After  the  planning team members  have
been  identified,  a team leader must  be
chosen and procedures for managing the
planning process must be  established.

2.3.1  Selecting a Team Leader
A community initiating a  hazardous mate-
rials  emergency  planning  process  may
choose to appoint an individual to facilitate
and lead the effort, or may appoint a  plan-
ning team and have the group decide who
will  lead the effort.  Either approach can
be used.  It is essential to establish clear
responsibility and authority for the project.
The chief  executive (or whoever initiates
the   process)  should  determine  which
course is  better suited  to  local circum-
stances.   (The emergency planning com-
mittee  required by Title  III of SARA is to
select  its  own chairperson).  Regardless
of how the team leader is selected,  it is
his  or  her primary responsibility to over-
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see the team's efforts through the entire
planning  process.  Because the role  of
leader is so  significant,  a co-chair  or
back-up  could also be named.

Five  factors are  of major  importance  in
selecting a team  leader:
    D   The degree of respect held for
         the person by groups with an in-
         terest in hazardous materials;

    D   Availability  of  time  and  re-
         sources;

    D   The person's history  of working
         relationships  with   concerned
         community agencies and organi-
         zations;

    D   The person's management and
         communication skills; and

    D   The person's existing responsi-
         bilities   related  to  emergency
         planning,  prevention,  and re-
         sponse.

Logical sources for a team leader include:
    D   The  chief  executive or other
         elected  official.   Leadership by
         a mayor, city or county council
         member, or other senior official
         is likely  to contribute  substan-
         tially  to  public confidence, en-
         courage  commitment  of   time
         and resources by  other key par-
         ties, and expedite  the implemen-
         tation of   program  initiatives.
         Discontinuity  in   the  planning
         process  can result, however,  if
         an elected official leaves office.

    D   A public safety department.  In
         most communities, the fire de-
         partment or police department
         bears principal responsibility for
         responding to incidents involving
         chemical releases and, typically,
         for inspecting facilities as  well.
         A  public   safety  department,
         therefore,  may  have personnel
         with  past  experience in emer-
         gency   planning   and  present
         knowledge of existing responsi-
         bilities within the community.
     D   The  emergency  management
         or civil defense agency.   In
         many communities,  officials  of
         such an agency will be  knowl-
         edgeable  and  experienced  in
         planning  for  major  disasters
         from a variety of causes.  One of
         the  primary responsibilities of a
         community's  emergency  man-
         agement coordinator is to guide,
         direct, and participate in the de-
         velopment  of  a  multi-hazard
         emergency operations plan.  In
         some States,  existing  laws re-
         quire that this agency  be the
         lead agency to prepare and dis-
         tribute emergency plans.

     D   The    local     environmental
         agency   or    public    health
         agency.  Persons with expertise
         and legal responsibility in  these
         areas will  have  special  knowl-
         edge about the risks posed by
         hazardous materials.

     D   A planning agency.  Officials in
         a planning agency will be familiar
         with the general planning proc-
         ess and with the activities and
         resources of the community.

     D   Others.  Communities should be
         creative and consider other pos-
         sible sources  for a team leader,
         such as civic  groups,  industry,
         academic  institutions, volunteer
         organizations,  and agencies not
         mentioned above. Experience in
         leading groups and committees,
         regardless of their purpose, will
         prove useful in emergency plan-
         ning.

Personal considerations as well as  institu-
tional ones should be weighed in selecting
a team leader.  For example, a particular
organization may appear to  have  all the
right resources for addressing hazardous
materials incidents.  But if the person  in
charge of that organization does not inter-
act well with other local officials, it might
be best to  look for a different leader.
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A response coordinator generally is knowl-
edgeable about emergency plans and  is
probably a  person who gets things done.
Be aware, however, that a good response
coordinator is not necessarily a good plan-
ner.  He or she might make a good chief
advisor  to someone better suited for the
team leader job.

2.3.2  Organizing for Planning Team Re-
      sponsibilities
The planning team must decide who shall
conduct the planning tasks and establish
the procedures  for monitoring and ap-
proving  the planning tasks.

^ A,  Staffing

There are three basic staffing approaches
that may be employed to  accomplish the
tasks involved  in emergency planning:
    D    Assign staff.   Previous experi-
         ence in  related planning efforts
         demonstrates the usefulness  of
         assigning one or more dedicated
         staff members to coordinate the
         planning  process and  perform
         specific  planning .tasks.    The
         staff  may  be assigned within a
         "lead agency" having related re-
        sponsibilities  and/or expertise,
        or  may  be  created separately
        through  outside  hiring  and/or
        staff  loans  from   government
        agencies or industry.

    D   Assign task forces  or commit-
        tees. Planning tasks can be per-
        formed by task forces or  com-
        mittees composed entirely or in
        part of members of the planning
        team.    Adding  knowledgeable
        representatives of  government
        agencies,   industry,   environ-
        mental, labor, and  other  com-
        munity organizations to the indi-
        vidual task forces or committees
        not only supplements  the  plan-
        ning  team  expertise  and re-
        sources,  but  also provides  an
        opportunity  for additional  inter-
        ested  parties to participate  di-
        rectly in the process.
    D   Hire contractors or consultants.
         If the personnel resources avail-
         able for the formation of a dedi-
         cated  staff and task forces or
         committees  are  limited,   and
         funds can be provided, the plan-
         ning team may elect to hire con-
         tractors  or consultants.  Work
         assigned  to a contractor  can
         range  from  a specialized  job,
         such as designing  a survey, to
         performing  an  entire  planning
         task (e.g., hazards identification
         and analysis).   A disadvantage
         of hiring contractors or consult-
         ants is that it does not help build
         a  community-centered  capabil-
         ity or planning  infrastructure.

The three approaches  presented above
are not mutually exclusive.  A community
may adopt any combination of  the ap-
proaches that best  matches its  own cir-
cumstances and resources.

^- 8.  Managing the Planning Tasks

The monitoring  and approval of  planning
assignments  are the central  responsibili-
ties of the planning team. In order to have
ongoing  cooperation in  implementing the
plan, it is recommended that the planning
team  operate  on  a  consensus  basis,
reaching  general agreement by all mem-
bers of the team.   Achieving consensus
takes  more time than majority voting, but
it is the best way to ensure that all repre-
sented parties have an opportunity to ex-
press their views and that  the decisions
represent and  balance  competing inter-
ests.  If it is determined that a consensus
method   is  inappropriate  or  impossible
(e.g., because of  the  multi-jurisdictional
nature of a  group), the planning team
should formally  decide how issues will be
resolved.

The team  leader should work  with  the
team  members  to  establish  clear goals
and deadlines for various  phases of the
planning  process. Progress toward these
goals  and deadlines should  be monitored
frequently.
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Planning meetings,  a necessary element
of the  planning  process,  often  do not
make  the  best  use of available  time.
Meetings can be unnecessarily long and
unproductive  if planning  members get
bogged down  on inappropriate side is-
sues. Sometimes, when several agencies
or groups sit down at one table, the meet-
ing can become a  forum for  expressing
political differences and other  grievances
fueled by long-standing interagency rival-
ries.  For a team to be effective, a strong
team leader will have to make sure that
meeting discussions  focus  solely  on
emergency  planning.

Another point to consider is that the team
approach  requires the melding of inputs
from different individuals, each with  a dif-
ferent  style and  sense of priorities.   A
team leader must  ensure that the  final
plan is consistent in  substance and  tone.
An editor may be used to  make sure that
the plan's grammar, style, and content all
ultimately fit well together.

On critical decisions, it  may be desirable
to extend the scope of participation be-
yond  the membership  of the  planning
team.  Approaches  that might  be used to
encourage community consensus building
through broadened  participation in the
process include invited reviews by key in-
terest groups, or formation of an advisory
council  composed  of  interested parties
that can independently  review  and  com-
ment  on  the  planning team's efforts.
Chapter 6  contains  further guidance on
consensus-building approaches.

The procedures to be used for monitoring
and   approving  planning   assignments
should be carefully thought out at the be-
ginning  of the planning process; planning
efforts work best when people understand
the ground rules and know when and how
they will be able to participate.  The moni-
toring and  approval  process can be ad-
justed at any time to accommodate vari-
ations in local interest.

Planning committees formed according to
Title  III of SARA are to  develop their own
rules.  These rules  include provisions for
public notification of committee activities;
public meeting to discuss the emergency
plan; public comments; response to pub-
lic comments by the committee; and dis-
tribution of the emergency plan.

^- C. The Use of Computers

Computers are handy tools  for both the
planning  process and  for maintaining re-
sponse   preparedness.    Because  new
technology is continually being developed,
this guide does not  identify specific hard-
ware or software packages that planning
teams  and/or  response personnel might
use.  Local  planners  should  consult Re-
gional FEMA or EPA  offices (see Appendix
F) for more detailed descriptions  of how
some communities are using computers.

The following list summarizes some ways
in which computers  are useful both in the
planning  process and  for maintaining re-
sponse preparedness.

    D    Word  processing.   Preparation
         and revision  of  plans is  expe-
         dited by word processing.   Of
         special interest to planners is the
         use of word processing to keep
         an  emergency plan  up  to  date
         on  an  annual or semiannual ba-
         sis.

    D    Modeling.  Planners might  con-
         sider  applying  air   dispersion
         models  for chemicals in  their
         community so that,  during an
         emergency,   responders  can
         predict the direction,  velocity,
         and  concentration  of   plume
         movement.   Similarly,  models
         can be developed to predict the
         pathways of  plumes in  surface
         water and ground water.

    D    Information access.  Respond-
         ers can use a personal comput-
         er on site to learn the identity of
         the chemical (s)  involved in the
         incident  (e.g.,  when  placards
         are  partially  covered),  the ef-
         fects of  the chemical (s)  on hu-
         man  health  and  the environ-
         ment,  and  appropriate counter-
         measures to contain and clean
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         up the chemical (s).  Communi-
         ties that intend to use computers
         on scene should also provide a
         printer on scene.

    D   Data storage. Communities can
         store  information  about  what
         chemicals are present in various
         local facilities, and  the availabil-
         ity of equipment and personnel
         that  are  needed   during   re-
         sponses to  incidents involving
         specific  chemical (s).  Compli-
         ance with  Title  III will generate
         large  amounts  of  data  (e.g.,
         MSDS forms, data  on  specific
         chemicals  in specific facilities,
         data  on  accidental  releases).
         (See Appendix  A.) Such data
         could  be  electronically  stored
         and retrieved. These data should
         be reviewed  and updated regu-
         larly.  Area maps with informa-
         tion  about transportation  and
         evacuation routes,  hospital  and
         school   locations,   and  other
         emergency-related information,
         can also be stored in computer
         disks.

State and  local planners with personal
computer communications capability  can
access  the  Federally operated   National
Hazardous Materials Information Exchange
(NHMIE)  by  dialing (312)  972-3275.  Us-
ers can  obtain up-to-date information on
hazmat  training  courses, planning tech-
niques,   events  and  conferences,  and
emergency  response  experiences  and
lessons   learned.    NHMIE  can also  be
reached through a toll-free telephone call
(1-800-752-6367;  in Illinois, 1-800-367-
9592).
                          2.4   Beginning  to Plan
When the planning team  members and
their leader  have  been identified and  a
process for  managing the planning tasks
is in place, the team should address sev-
eral interrelated  tasks.   These planning
tasks are described in the next chapter.
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                3.  Tasks of the Planning Team
                             3.1  Introduction
The major tasks of the planning  team in
completing hazardous materials planning
are:
    D   Review of existing plans, which
         prevents plan overlap and incon-
         sistency,  provides useful  infor-
         mation and ideas, and facilitates
         the coordination  of the plan with
         other plans;

    D   Hazards  analysis, that includes
         hazards identification, vulnerabil-
         ity analysis, and  risk analysis;

    D   Assessment  of  preparedness,
         prevention, and  response capa-
         bilities,  that identifies  existing
         prevention measures and  re-
         sponse  capabilities   (including
         mutual aid agreements),  and as-
         sesses their adequacy;

    D   Completion of hazardous mate-
         rials planning that describes the
         personnel, equipment, and pro-
         cedures  to be  used in case of
         accidental release of a hazard-
         ous material; and

    D   Development  of  an  ongoing
         program  for plan  implementa-
         tion/maintenance,  training, and
         exercising.

This chapter discusses the planning tasks
that are conducted prior to the prepara-
tion of the emergency plan.   Chapters 4
and 5 provide guidance on  plan  format
and content.   Chapter 6  discusses  the
team's responsibilities for  conducting in-
ternal and external reviews, exercises, in-
cident reviews, and training.  This chapter
begins with a discussion of the organiza-
tional   responsibilities  of  the  planning
team.
                     3.2  Review  of Existing Plans
Before undertaking any other work,  steps
should be taken to search out and review
all existing  emergency plans.  The main
reasons for reviewing these plans are (1)
to minimize work efforts by building upon
or modifying existing emergency planning
and response information and  (2) to en-
sure proper coordination with other re-
lated plans.  To the extent possible, cur-
rently used plans  should be amended to
account for the special problems posed
by hazardous materials, thereby avoiding
redundant emergency  plans.  Even plans
that  are  no  longer used  may  provide a
useful starting point.  More general plans
can also be a source of  information and
ideas.    In  seeking  to  identify  existing
plans, it will be helpful to consult organiza-
tions such as:

    D    State and local emergency man-
         agement agencies;

    D    Fire department?;

    D    Police departments;
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     D   State  and  local environmental
         agencies;

     D   State  and  local transportation
         agencies;

     D   State  and  local public  health
         agencies;

     D   Public service agencies;

     D   Volunteer groups, such  as the
         Red Cross;

     D   Local industry and industrial as-
         sociations; and

     D   Regional offices of Federal agen-
         cies such as EPA and FEMA.
When reviewing the existing plans of local
industry and industrial associations, the
planning team should obtain a copy of the
CAER  program  handbook  produced  by
CMA.  (See Section 1.5.4.)  The  hand-
book provides useful information and en-
courages  industry-community  coopera-
tion in  emergency planning.

In  addition  to the  above organizations,
planning teams should coordinate with the
RRTs and  OSCs  described  in Section
1.4.1.  Communities can contact or obtain
information on the RRT and OSC covering
their area through the EPA Regional office
or USCG district office.  (See Appendix F
for a list of these contacts.)
                          3.3   Hazards Analysis:
 Hazards  Identification, Vulnerability Analysis, Risk Analysis
A hazards analysis is a critical component of planning for hazardous materials releases.
The information developed in a  hazards  analysis provides both the factual basis to set
priorities for planning and also the necessary documentation for supporting hazardous
materials planning and  response efforts.

There are several concepts involved in analyzing the dangers posed by hazardous materi-
als.  Three terms — hazard, vulnerability, risk — have different technical meanings but
are sometimes used interchangeably.  This  guidance adopts the following definitions:

    D   Hazard. Any situation that has the potential for causing injury to life,  or damage
         to property and the environment.

    D   Vulnerability.  The susceptibility of life, property, and the environment to injury or
         damage  if a hazard manifests its potential.

    D   Risk. The probability that injury  to life, or damage to property and the environ-
         ment will occur.

A hazards analysis may include vulnerability analysis and risk analysis,  or it may simply
identify  the nature and location of hazards  in the  community.  Developing a complete
hazards analysis that examines all hazards, vulnerabilities,  and risks may be neither possi-
ble nor  desirable.  This may be particularly  true for smaller communities that have less
expertise and fewer resources to contribute  to the  task.  The planning team must deter-
mine the level of thoroughness that is appropriate.   In any case, planners should ask local
facilities whether they have already completed a facility hazards analysis.  Title III requires
facility owners or operators to provide to local emergency planning committees informa-
tion  needed for the planning process.
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As important as knowing how to perform a hazards analysis is deciding how detailed an
analysis to conduct. While a complete analysis of all hazards would be informative, it may
not be feasible or practical given resource and time constraints.  The value of a limited
hazards analysis should not be  underestimated.  Often the examination of only major
hazards is necessary, and  these may be studied without undertaking an elaborate risk
analysis.  Thus, deciding what is really needed and what can be afforded is an important
early step in the hazards analysis process.  In fact, the  screening of hazards and setting
analysis priorities is an essential task of the planning team.
The costs of hazards analysis can and often should be reduced by focusing on the haz-
ards posed by only the most common and/or most hazardous substances. A small num-
ber of types of hazardous materials account for the vast majority of incidents and risk.
The experience from  DOT'S Lessons Learned is that the most prevalent dangers from
hazardous materials are posed by common  substances, such as gasoline, other flamma-
ble materials,  and a few additional chemicals.  The CEPP technical guidance presents a
method that may be used to assist in ranking  hazards posed by less  prevalent but  ex-
tremely hazardous substances,  such as  liquid chlorine,  anhydrous ammonia, and hydro-
chloric and sulfuric acids.

A hazards analysis can be greatly simplified by using qualitative methods (i.e., analysis
that is based on judgment rather than measurement of quantities involved). Smaller com-
munities may  find that their fire and police chiefs can provide highly  accurate assess-
ments of the  community's hazardous materials problems.  Other, larger communities
may have the expertise and resources to utilize  quantitative techniques but may decide to
substitute qualitative methods in their place should it be cost effective to do so.

Simple  or sophisticated, the hazards analysis  serves to characterize  the nature of  the
problem posed by hazardous materials.  The information that is developed in the hazards
analysis should then be used by the planning team to orient planning appropriate to  the
community's situation. Do not commit valuable resources to plan development until a
hazards analysis  is  performed.

3.3.1  Developing the Hazards Analysis
The procedures that are presented in this  section are intended  to provide a simplified
approach to hazards analysis for both facility and  transportation hazards.  Communities
undertaking a  hazards analysis should refer  to CEPP technical guidance for fixed facilities
and to Lessons Learned and Community Teamwork for transportation.

The components  of a hazards analysis include the concepts of hazard, vulnerability, and
risk.  The discussion that follows summarizes the  basic procedures for conducting each
component.

^ A. Hazards Identification
The hazards identification provides information on the facility and transportation situations
that have the potential for causing injury to  life, or damage to property and the environ-
ment due to a hazardous materials  spill or release.  The hazards identification  should
indicate:

     D   The  types  and quantities of  hazardous materials located  in  or transported
         through  a community;
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     D   The location of hazardous materials facilities and routes; and
     D   The nature of the hazard (e.g., fire, explosions)  most likely to accompany haz-
         ardous materials spills or releases.
To develop this information, consider hazardous materials at fixed sites and those that are
transported by highway,  rail, water, air, and pipeline.  Examine hazardous materials at:
     D   Chemical plants;
     D   Refineries;
     D   Industrial facilities;
     D   Petroleum and  natural  gas tank farms;
     D   Storage facilities/warehouses;
     D   Trucking terminals;
     D   Railroad yards;
     D   Hospital, educational, and governmental facilities;
     D   Waste disposal and treatment facilities;
     D   Waterfront  facilities,  particularly commercial marine terminals;
     D   Vessels in  port;
     D   Airports;
     D   Nuclear facilities;  and
     D   Major transportation  corridors and transfer points.
For individual facilities, consider hazardous materials:
     D   Production;
     D   Storage;
     D   Processing;
     D   Transportation;  and
     D   Disposal.
Some situations will  be obvious. To identify the less obvious ones, interview fire and
police chiefs, industry leaders, and reporters; review news releases and fire and police
department records  of past incidents.  Also,  consult lists of hazardous chemicals that
have been identified  as a result of compliance with right-to-know laws.  (Title III of SARA
requires facility owners and operators  to submit to the local emergency planning commit-
tee a material safety data sheet for specified chemicals, and emergency and hazardous
chemical inventory forms. Section 303 (d) (3) of Title III states  that "upon  request from
the emergency planning  committee, the owner or operator of the facility shall promptly
provide information... necessary for developing and implementing the emergency plan.")
Use the CEPP technical guidance for  help in evaluating  the hazards associated with air-
borne releases of extremely hazardous substances.
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The hazards identification should result in compilation of those situations that pose the
most serious threat of  damage to the community.  Location maps and charts are an
excellent means of depicting this information.
^ B. Vulnerability Analysis
The vulnerability analysis identifies what in the community is susceptible to damage should
a hazardous materials release occur.  The vulnerability analysis should provide informa-
tion on:

    D   The extent of the vulnerable zone (i.e., the significantly affected area) for a spill
         or release and the conditions that influence the  zone of impact  (e.g., size of
         release, wind direction);

    D   The population, in terms of size and types (e.g., residents, employees,  sensi-
         tive populations — hospitals, schools, nursing  homes, day care centers), that
         could be expected to be within the vulnerable zone;

    D   The private and public property (e.g., homes, businesses, offices) that may be
         damaged, including essential support systems (e.g., water, food, power, medi-
         cal) and transportation corridors;  and

    D   The environment that may be affected, and the impact on sensitive natural areas
         and endangered species.

Refer to the CEPP technical guidance or DOT's Emergency  Response Guidebook to obtain
information on the vulnerable zone for a hazardous materials release.  For information on
the population, property, and  environmental resources within the  vulnerable zone, con-
sider  conducting:

    D   A windshield survey of the area (i.e., first hand observation by driving through
         an area);

    D   Interviews of fire, police, and planning department personnel; and

    D   A review of planning department documents, and  statistics on land use, popula-
         tion, highway usage,  and the area's infrastructure.

The vulnerability analysis should  summarize information on all hazards determined to be
major in the hazards identification.

^ C.  Risk Analysis
The risk analysis assesses the probability of damage (or injury) taking  place in the com-
munity due to a hazardous materials release and the actual damage (or injury) that might
occur, in light of the vulnerability analysis.  Some planners may choose to analyze worst-
case scenarios.  The risk  analysis may provide information on:

    D   The probability that a release will  occur  and any  unusual environmental condi-
         tions, such as areas in flood plains, or the possibility of simultaneous emergency
         incidents (e.g., flooding or fire hazards resulting in release of hazardous materi-
      .   als);

    D   The type of harm to people (acute, delayed, chronic) and the associated high-
         risk groups;

    D   The type of damage  to property  (temporary, repairable,  permanent); and


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     D   The type of  damage to the environment (recoverable, permanent).
Use the Chemical Profiles  in the CEPP technical  guidance or a similar  guide to obtain
information on  the type of risk associated with  the accidental airborne release of ex-
tremely hazardous substances.

Developing occurrence probability data may not be feasible for all communities.  Such
analysis can require specialized expertise not available to a community. This is especially
true of facility releases which call for detailed analysis by competent safety engineers and
others (e.g., industrial hygienists) of the operations and associated risk factors of the
plant and engineering system in  question  (refer to the American  Institute  of Chemical
Engineers' Guidelines for Hazard Evaluation Procedures).  Transportation  release analysis
is more straightforward, given the substantial research and established  techniques that
have been developed in this area (refer to Community Teamwork and Lessons Learned).

Communities should not be overly concerned with developing elaborate quantitative re-
lease probabilities.  Instead, occurrence  probabilities can be described in relative terms
(e.g., low, moderate, high).  The emphasis should be on developing reasonable esti-
mates based on the best available expertise.

3.3.2  Obtaining  Facility Information
The information that is needed about a facility for hazards analysis may already be assem-
bled as a result of previous efforts. As indicated in Section 1.4.1, industry is required by
Title III of SARA to provide inventory and release information to the appropriate emergency
planning  committee.  Local emergency planning committees are specifically entitled to
any information from facility owners and operators deemed necessary for developing and
implementing the emergency plan. The EPA Administrator can order facilities to comply
with a local committee's  requests for necessary information;  local  planning committees
can bring a civil suit against a facility that refuses to provide requested information. Some
State and local  governments have adopted community  right-to-know legislation.  These
community right-to-know provisions  vary, but they generally  require industry and other
handlers of hazardous materials to provide information to State or local authorities and/or
the public about hazardous  materials  in the community.  Wisconsin, for example, requires
all hazardous materials spills to be reported to a State agency.  Such requirements pro-
vide a data base that the planning team can use to determine the types  of releases that
have occurred in  and around the  community.

Requesting information from a  facility for  a hazards analysis can be an opening for con-
tinuing dialogue within the community.  The information should be sought in such a way
that facilities are encouraged to cooperate and participate actively in the planning process
along with governmental agencies and other community groups.  Respecting a commer-
cial facility's needs to protect confidential  business information (such as sensitive process
information) will encourage  a facility to be forthcoming with the information necessary for
the community's  emergency planning. The planning team can learn what the facility is
doing and what measures have been put in place to reduce risks, and also identify what
additional resources such as personnel, training, and equipment are needed in the com-
munity.   Because facilities use  different kinds  of hazard assessments (e.g., HAZOP,
Fault-tree analysis), local planners need  to indicate specifically what categories of infor-
mation they are interested  in receiving.  These  categories may include:

     D   Identification of chemicals of concern;
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     D   Identification of serious events that can lead to releases (e. g., venting or sys-
         tem leaks,  runaway chemical reaction);

     D   Amounts of toxic material  or energy (e. g., blast, fire radiation) that could be
         released;

     D   Predicted consequences of the release  (e. g., population exposure illustrated
         with plume maps and damage rings) and associated damages (e. g., deaths,
         injuries);

     D   Whether the possible consequences are considered acceptable by the facility;
         and

     O   Prevention measures in place on site.

The facilities themselves are a useful resource; the community should work with the facil-
ity personnel and utilize their expertise.  The assistance that a facility can provide in-
cludes:

     D   Technical experts;

     D   Facility emergency plans;

     D   Cleanup and recycling capabilities;

     D   Spill prevention control and countermeasures (SPCC);

     D   Training and safe handling  instructions; and

     D   Participation in developing  the emergency  plan, particularly in defining how to
         handle spills on company property.

Cooperative programs such as CMA's  CAER  program are also a source for hazard infor-
mation. One of the major objectives of the CAER program is to improve local emergency
plans by combining chemical plant emergency plans with other  local planning to achieve
an integrated community emergency plan. The planning team should ask the facility if it is
participating in  the CAER program;  this may stimulate non-CMA  members to  use the
CAER approach.  If a facility is participating in the CAER program,  the emergency plans
developed by the facility will serve as  a good starting point  in information gathering and
emergency planning. The CAER program handbook also encourages companies to per-
form hazards analyses of their operations. Local  planners should ask facilities if they have
adhered to this recommendation and  whether they  are willing to share results  with the
planning team.

3.3.3  Example Hazards Analysis
Exhibit 3 presents an example of a very simple hazards analysis for a hypothetical com-
munity.  Hazards A,  B,  and  C are identified as three among other major hazards in the
community.  Information for the exhibit could have been obtained from windshield surveys
of the area; the CEPP technical guidance; information gained from facilities under Title III
provisions; and/or interviews with fire,  police, county planners, and facility  representa-
tives.  These interviews also could have provided input into the exhibit's qualitative as-
sessments of hazard occurrence.

Once completed, the hazards analysis is an essential tool  in the  planning process.  It
assists the planning team to decide:
                                     Page 25

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                                                                                            Exhibit  3
                                           EXAMPLE HAZARDS ANALYSIS  FOR A HYPOTHETICAL  COMMUNITY
                                                                        Hazard A
                                                 Hazard  B
                                                  Hazard  C
                   1.  HAZARDS  IDENTIFICATION
                       (MAJOR HAZARDS)
                       a.  Chemical

                       b.  Location
Chlorine

Water treatment plant
Ammonia

Tank truck on local Interstate highway
Liquid methyl Isocyanate (MIC)

Pesticide manufacturing plant In nearby
semi-rural area
                       c.  Quantity

                       d.  Properties
 a
OQ
2000 Ibs

Poisonous; may be fatal if Inhaled. Res-
piratory conditions aggravated by expo-
sure.  Contact may cause burns to skin
and eyes.  Corrosive.  Effects may be
delayed.
5000 Ibs

Poisonous; may be fatal if Inhaled. Va-
pors cause Irritation of eyes and respira-
tory tract.   Liquid will  burn skin and
eyes.  Contact with  liquid  may  cause
frostbite. Effects may be delayed. Will
burn within certain vapor concentration
limits and Increase fire hazard  In the
presence of oil or other combustible ma-
terials.
5000 Ibs

Causes death by respiratory distress af-
ter Inhalation.    Other health  effects
would  include permanent eye damage,
respiratory distress, and disorientation.
Explosive. Extremely flammable.
                   2.  VULNERABILITY ANALYSIS
 Os
                       a.  Vulnerable zone
                       b.  Population  within
                           vulnerable zone
                                                              A spill of 2000 Ibs of chlorine from a
                                                              storage tank could result in an area of
                                                              radius 1650 feet (0.3 miles) where chlo-
                                                              rine gas may exceed the  level of con-
                                                              cern.
Approximately 500 residents of a nurs-
ing home; workers at small factory.
                                         A spill of 5000 Ibs of ammonia resulting
                                         from a collision of a tank truck could re-
                                         sult In an area of radius 1320 feet (0.25
                                         miles) where ammonia exceeds its level
                                         of concern.
Up to 700 persons in residences, com-
mercial  establishments,  or  vehicles
near highway interchange. Seasonal in-
flux of visitors to forest preserve in the
fall.
A spill of 5000 Ibs of methyl Isocyanate
could affect an area of radius 3300 feet
(0.6 miles)  with  MIC vapors exceeding
the level of concern (assuming that the
liquid is hot when spilled, the tank Is not
diked, and the MIC  is at 100% concen-
tration).

Up to 200 workers at the plant and 1000
children in a school.
                       c.  Private and public
                           property that may
                           be damaged
Facility equipment, vehicles,  and struc-
tures susceptible to damage from corro-
sive fumes.  Community's water supply
may be temporarily affected  given that
the facility is its primary supplier.  Mix-
ture with fuels may cause an explosion.
 25 residences,  2 fast food restaurants,
one 30 room motel, a truck stop, a gas
station  and a mini-market.   Highway
and nearby vehicles may be susceptible
to damage from a  fire or explosion re-
sulting from the collision.
Runoff to a sewer may cause an explo-
sion hazard as MIC reacts violently with
water.
                       d.  Environment that may
                           be affected
                                                              Terrestrial life.
                                         Adjacent forest  preserve is highly sus-
                                         ceptible to forest fires especially during
                                         drought conditions.
                                                                                                                                               Nearby farm animals.

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                                                                                   Exhibit 3  (Continued)
                                          EXAMPLE  HAZARDS ANALYSIS FOR A  HYPOTHETICAL COMMUNITY
                                                                       Hazard A
                                                 Hazard B
                                                 Hazard  C
                   3.   RISK ANALYSIS
                       a.   Probability of
                           hazard occurrence
Low — because chlorine is stored in an
area with leak detection equipment in 24
hour service  with  alarms.  Protective
equipment is kept outside storage room.
High — Highway Interchange has a his-
tory of accidents due to poor visibility of
exits and entrances.
Low — facility has up to date contain-
ment  facilities  with  leak  detection
equipment, and an emergency plan for
its employees. There are good security
arrangements that would deter tamper-
Ing or accidents resulting from civil up-
risings.
                       b.
                           Consequences If
                           people are exposed
High levels of chlorine gas in the nursing
home and factory could cause death and
respiratory distress.  Bedridden nursing
home patients are especially suscepti-
ble.
Release of  vapors and subsequent fire
may cause traffic  accidents.  Injured
and trapped motorists are subject to le-
thal  vapors and  possible Incineration.
Windblown vapors can cause respiratory
distress for nearby residents and busi-
ness patrons.
If accident occurs while school Is In ses-
sion, children could be killed,  blinded,
and/or suffer chronic debilitating respi-
ratory problems.  Plant  workers would
be  subject to  similar effects  at  any
time.
a
00
 X)
                       d.
                           Consequences for
                           property
                           Consequences of
                           environmental
                           exposure
Possible superficial damage to facility
equipment and structures from corrosive
fumes (repairable).
Possible  destruction
fauna and flora.
                                                                                  of  surrounding
Repairable damage to highway. Poten-
tial destruction of nearby vehicles due to
fire or explosions.
Potential for  fire  damage to adjacent
forest preserve due to combustible ma-
terial  (recoverable in the long term).
Vapors may explode In a confined space
causing property damage  (repairable).
Damage could result from fires (repair-
able).
Farm animals and other fauna could be
killed or suffer health effects necessi-
tating  their destruction or indirectly
causing death.
                           Probability of
                           simultaneous
                           emergencies
                                                             Low
                                                                                                     High
                                                                                                                                             Low
                       f.   Unusual
                           environmental
                           conditions
                                                             None
                                        Hilly terrain prone to mists, thus creat-
                                        ing adverse driving conditions.
                                        Located In a 500 year river flood plan.

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     D   The level of detail that is necessary;

     D   The types of response to emphasize; and

     D   Priority hazards or areas for planning.

The examples presented in Exhibit 3 illustrate the basic fact that there are no hard and fast
rules for weighing the relative importance of different types of hazards in the context of
the planning  process.  Compare  example hazards B and C in the exhibit.  Hazard C
involves a substance,  methyl isocyanate (MIC), whose lethal  and severe chronic effects
were evident at Bhopal.  As described in the example, an MIC  release could affect 200
plant workers and 1000 children in a nearby school.  By contrast, the ammonia in example
hazard B is less lethal than MIC and threatens fewer people.   With just this information in
mind, a planner might  be expected to assign the MIC a higher  planning priority than he
would the ammonia.  Consider now the "probability  of occurrence." In example C, plant
safety and  prevention measures are excellent, and an MIC  incident is correspondingly
unlikely  to occur. On the other hand, poor highway construction and weather conditions
that  affect visibility make an ammonia incident (example hazard B) far more probable.
Planners must balance all factors when deciding whether to give planning priority to B or
C.  Both situations are dangerous and require emergency planning.  Some would argue
that  the  lethality of MIC outweighs the presence of good safety and  prevention proce-
dures; others would argue that the frequency of highway interchange accidents is reason
enough  to place greater emphasis on planning to deal with an ammonia incident.   Each
planning team must make such judgments on priorities in light  of local circumstances.

Before initiating plan development,  the planning team should complete an assessment of
available response resources, including  capabilities provided through  mutual aid agree-
ments.  Guidance for conducting such an assessment is presented in the following sec-
tion.
                       3.4   Capability Assessment
This section contains sample questions to help the planning team evaluate preparedness,
prevention, and response resources and capabilities.  The section  is divided into three
parts.  The first part covers questions that the planning team can ask a technical repre-
sentative from a  facility  that may need  an emergency plan.  The second part  includes
questions related  to transportation.

The third part addresses  questions to a  variety of response and government agencies,
and is  designed to help identify all resources within a  community.  This information will
provide direct input into the development of the hazardous materials  emergency plan and
will assist the planning team in evaluating what additional emergency response resources
may be needed by the community.

3.4.1   Facility Resources
What is the status of the  safety plan (also referred to  as  an emergency or contingency
plan) for the facility? Is the safety plan consistent- with  any community emergency plan?

    D   Is there  a list of potentially toxic chemicals available?  What are their  physical
        and chemical characteristics,  potential for causing adverse health effects,  con-
                                     Page 28

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    trols, interactions with other chemicals? Has the facility complied with the com-
    munity right-to-know provisions of Title III of SARA?

D  Has a hazards analysis  been prepared for the facility?  If so, has it been up-
    dated?  Has a copy been provided to the local emergency planning committee?

D  What steps  have been taken to reduce identified risks?

D  How does the company reward good safety records?

D  Have operation or storage procedures been modified to reduce the probability of
    a release and minimize  potential effects?

D  What release prevention or mitigation systems, equipment, or procedures are in
    place?

D  What possibilities are there for safer substitutes for any acutely toxic chemicals
    used or stored at the facility?

D  What possibilities exist for reducing the volume of the hazardous materials in use
    or stored at the facility?

D  What additional safeguards  are available to prevent accidental releases?

D  What studies have been conducted by the facility to determine the feasibility of
    each of the following approaches for each relevant production process or opera-
    tion:   (a)  input change, (b)  product reformulation, (c) production process
    change,  and (d) operational improvements?

D  Are on-site  emergency response equipment (e.g., fire fighting equipment, per-
    sonal protective equipment, communications equipment)  and trained personnel
    available to  provide on-site initial response efforts?

D  What equipment (e.g., self-contained breathing apparatus, chemical suits, un-
    manned fire monitors, foam deployment systems, radios,  beepers) is available?
    Is equipment available for loan or use by the community on a reimbursable ba-
    sis?  (Note:  Respirators should not be lent to any person  not properly trained in
    their use.)

D  Is there emergency medical care on site?

D  Are the local hospitals prepared to accept and provide care to patients who have
    been exposed to chemicals?

D  Who  is the  emergency contact for the site  (person's  name,  position, and
    24-hour telephone number)  and what is the chain of command during an emer-
    gency?

D  Are employee evacuation plans in effect and are  the employees trained to use
    them in the  event of an  emergency?

D  What kinds of notification systems connect  the facility and the local community
    emergency  services (e.g.,  direct alarm, direct telephone hook-up, computer
    hook-up)  to address emergencies on  site?

D  What is the  mechanism  to alert employees and the surrounding  community in
    the event of a release at the facility?
                                Page 29

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     D   Is there a standard operating procedure for the personal protection of commu-
         nity members at the time of an emergency?

     D   Does the community know about the meaning of various alarms or warning sys-
         tems? Are tests conducted?

     D   How do facility personnel coordinate with the  community government and local
         emergency and medical services during emergencies? Is overlap avoided?

     D   What mutual aid agreements are in place for  obtaining emergency response
         assistance from other industry members? With whom?

     D   Are there any contacts or other pre-arrangements in place with specialists for
         cleanup and removal of releases, or is this handled in-house? How much time is
         required for the cleanup specialists to respond?

     Q   What will determine concentrations of released chemicals existing at the site?
         (Are there toxic gas detectors, explosimeters, or other detection devices posi-
         tioned around the facility? Where are they located?)

     D   Are wind direction indicators positioned within the facility perimeter to determine
         in what direction a released chemical will travel?  Where are they located?

     D   Is there capability for modeling vapor cloud dispersion?

     D   Are auxiliary power systems available to perform emergency system functions in
         case of power outages at the facility?

     D   How often  is the safety plan tested and updated?  When was it last tested and
         updaied?

     D   Does the company participate in CHEMNET or the CAER  program?

     D   Does the company have the capability and plans for responding to off-site emer-
         gencies?  Is this limited to the company's products?
What is the safety training plan for management and employees?
     D    Are  employees trained in the use of emergency response equipment, personal
         protective equipment, and emergency procedures detailed  in the  plant safety
         plan?  How often is training  updated?

     D    Are  simulated emergencies conducted for training  purposes? How often? How
         are these simulations evaluated and by whom?  When was this last done?  Are
         the  local community emergency response and medical  service organizations
         invited to participate?

     D    Are  employees given training in methods  for coordinating with local community
         emergency response and medical services during emergencies?  How  often?

     D    Is management given appropriate training? How frequently?

Is there an emergency response equipment and systems inspection plan?
     D    Is there a  method for identifying emergency response equipment problems?
         Describe it.

     D    Is there testing of on-site alarms, warning signals, and  emergency  response
         equipment? How often is this equipment tested and replaced?
                                    Page 30

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3.4.2  Transporter Resources
What cargo information and response organization do ship,  train, and  truck operators
provide at a release?

     D   Do transport shipping  papers  identify hazardous materials, their physical and
         chemical characteristics, control techniques, and interactions with other chemi-
         cals?

     D   Do transports have proper placards?

     D   Are there standard operating  procedures (SOPs) established for release situ-
         ations?  Have these procedures been updated to reflect current cargo charac-
         teristics?

     D   Who is the emergency contact for transport operators?  Is there a 24-hour
         emergency contact system in place? What is the transport operation's chain of
         command in responding to a release?

What equipment and cleanup capabilities can transport operations make available?

     D   What emergency response equipment is carried by each transporter (e.g., pro-
         tective clothing, breathing apparatus, chemical extinguishers)?

     D   Do transports have first-aid equipment (e.g., dressings for chemical burns, and
         water  to rinse off toxic chemicals)?

     D   By what means do operators communicate with emergency response authori-
         ties?

     D   Do transport operations have their own emergency response units?

     D   What arrangements have been  established with cleanup specialists for removal
         of a release?

What is the safety training plan for  operators?

     D   Are operators trained in release SOPs and to use emergency response equip-
         ment?  How often is training updated?

     D   How often are release drills conducted?  Who evaluates these drills and do the
         evaluations  become a part of an employee's file?

     D   Are safe driving practices  addressed in operator training?  What monetary  or
         promotional incentives encourage safety in transport operation?

Is there a transport and emergency response equipment inspection plan?

     D   What inspections are conducted? What leak detection and equipment readiness
         tests are done?  What is the schedule for inspections and tests?

     D   Are problems identified in  inspections corrected? How are maintenance sched-
         ules established?
                                     Page 31

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3.4.3.  Community Resources
What local agencies make up the community's existing response preparedness network?
Some examples include:

     D   Fire department;

     D   Police/sheriff/highway patrol;

     D   Emergency medical/paramedic service  associated with local hospitals or fire
         and police departments;

     P   Emergency management or civil defense agency;

     D   Public health agency;

     D    Environmental agency;

     D    Public works and/or transportation departments;

     n    Red Cross;  and

     D    Other local community resources such as public housing, schools, public utili-
         ties,  communications.

What is the capacity and level of expertise of the community's emergency medical facili-
ties, equipment, and personnel?

Does the community have arrangements or mutual aid agreements for assistance with
other jurisdictions or organizations (e.g., other communities, counties, or States; indus-
try; military installations; Federal  facilities; response organizations)?  In the absence of
mutual aid agreements,  has the community taken liability into consideration?

What is the current status of community planning and coordination for hazardous materi-
als emergency preparedness?  Have  potential overlaps in planning been avoided?

     D    Is there a community planning and coordination body (e.g., task force, advisory
         board, interagency committee)?  If so, what is the defined structure and author-
         ity of the body?

     D    Has the community performed any assessments of existing  prevention and re-
         sponse capabilities within its own emergency response  network?

     D    Does the community maintain  an up-to-date  technical  reference library  of re-
         sponse procedures  for hazardous materials?

     D    Have there  been any training seminars, simulations,  or mock  incidents per-
         formed by the  community in conjunction with local industry or other organiza-
         tions? If so, how frequently are they conducted?  When was this last done? Do
         they typically have simulated casualties?

Who are the specific community points of contact and what are their responsibilities in an
emergency?

     D    List  the  agencies involved,  the area of responsibility (e.g., emergency re-
         sponse, evacuation,  emergency shelter, medical/health care, food distribution,
         control access to accident site,  public/media  liaison,  liaison with  Federal and
         State responders, locating and manning the command center and/or emer-
                                    Page 32

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         gency operating center), the name of the contact, position, 24-hour telephone
         number, and the chain of command.

    D   Is there any specific chemical or toxicological expertise available in the commu-
         nity, either in industry, colleges and universities, poison control centers,  or on a
         consultant basis?

What kinds of equipment and materials are available at the local level to respond to emer-
gencies?  How can the equipment, materials, and personnel be made available  to trained
users at the scene of an incident?

Does the community have specialized emergency response teams to respond to hazard-
ous materials releases?

    D   Have the local  emergency services  (fire,  police,  medical) had any hazardous
         materials training, and if so, do they have and use any specialized  equipment?

    D   Are local hospitals able to decontaminate and treat numerous exposure  victims
         quickly and effectively?

    D   Are  there  specialized industry response teams (e.g.,  CHLOREP,  AAR/BOE),
         State/Federal response teams, or contractor response teams available within or
         close to  the community?  What is the average time for them to arrive on the
         scene?

    D   Has  the  community sought any  resources  from industry to help  respond to
         emergencies?

Is the community  emergency transportation network defined?

    D   Does the community have specific evacuation routes designated?  What are
         these evacuation routes?  Is the general public aware of these routes?

    D   Are there specific access routes designated for emergency response  and serv-
         ices personnel to reach facilities or incident sites?  (In a real incident, wind direc-
         tion  might  make certain routes unsafe.)

Does the community have other procedures for protecting citizens during emergencies
(e.g., asking them to remain indoors, close windows, turn off air-conditioners, tune into
local emergency radio broadcasts)?

Is there a mechanism that enables responders to exchange information or ideas during an
emergency with other entities, either internal  or external to the  existing organizational
structure?

Does the community have a communications link with an Emergency  Broadcast System
(EBS) station? Is there a designated emergency communications network in the commu-
nity to alert the public, update the public, and provide communications between the com-
mand center and/or emergency operating center, the incident site, and off-scene sup-
port?  Is  there a back-up system?

    D   What does the  communications network involve (e.g., special radio frequency,
         network channel, siren, dedicated phone lines, computer hook-up)?

    D .  Is there an up-to-date list, with telephone numbers, of radio  and television sta-
         tions  (including cable companies)  that broadcast in the area?
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    D   Is there an up-to-date source list with a contact,  position, and telephone num-
         ber for technical information assistance)? This can be Federal (e.g., NRC, USCG
         CHRIS/HAGS,   ATSDR,   OHMTADS),   State,  industry   associations  (e.g.,
         CHEMTREC, CHLOREP, AAR/BOE, PSTN),  and local  industry groups (e.g.,  local
         AlChE, ASME, ASSE chapters).

Is there a source list with a contact, position, and telephone number for community re-
sources available?

    D   Does the list of resources include: wreck clearing, transport, cleanup, disposal,
         health, analytical sampling laboratories, and detoxifying agents?

Have there been any fixed facility or transportation incidents involving hazardous materials
in the community?  What response efforts were taken? What were the results?  Have
these results been  evaluated?
                    3.5  Writing an Emergency Plan
When  the  team  has  reviewed  existing
plans,  completed  a hazards identification
and analysis, and assessed its prepared-
ness, prevention,  and response capabili-
ties, it can take steps to make serious in-
cidents less  likely.  Improved warning sys-
tems,  increased  hazardous materials
training of  industry and local response
personnel, and other efforts at the local
level, can all  make a  community better
prepared to live safely with hazardous ma-
terials.  The  team should also begin to
write an emergency plan  if one does not
already exist, or revise existing plans to
include hazardous  materials.   Chapter 4
describes  two approaches to developing
or revising an emergency  plan.  Chapter 5
describes  elements related to  hazardous
materials  incidents that  should  be  in-
cluded in whichever type of plan the com-
munity chooses to  write.
                                    Page 34

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                      4.  Developing  the Plan
                             4.1   Introduction
Most communities have some type of writ-
ten plan for emergencies.  These  plans
range from a comprehensive multi-hazard
approach  as  described  in FEMA's CPG
1-8 (Guide for Development of State and
Local  Emergency Operations Plans) to a
single telephone roster  for call-up pur-
poses, or an  action checklist. Obviously
the more  complete and  thorough a plan
is, the  better prepared the  community
should be to deal with any emergency that
occurs.

As noted in Chapter 1, the " Emergency
Planning  and  Community Right-to-Know
Act of 1986"  requires local emergency
planning  committees  to develop  local
plans  for  emergency responses in the
event of a release of an extremely hazard-
ous substance.  Those communities re-
ceiving FEMA  funds are required  to incor-
porate hazardous materials planning into
their multi-hazard emergency operations
plan  (EOP).   Other communities are en-
couraged to prepare a multi-hazard EOP
in accord with CPG 1 -8 since it is the most
comprehensive  approach to emergency
planning. Not every community, however,
may be ready for or capable of  such a
comprehensive approach. Because each
community must plan  in light of  its own
situation and resources, a less exhaustive
approach may be the only practical, real-
istic way of having some type of near-
term plan.  Each community must  choose
the level of planning that is appropriate for
it, based upon the types of hazard found
in the community.

This chapter discusses two  basic  ap-
proaches to writing a  plan:  (1) develop-
ment or revision of a hazardous materials
appendix (or appendices to functional an-
nexes) to a multi-hazard EOP following
the approach described in FEMA's CPG
1-8, and (2) development or revision of a
plan covering only hazardous materials.
Each approach is discussed in more detail
below.
    4.2  Hazardous Materials Appendix to Multi-Hazard EOP
The first responders (e.g., police, fire,
emergency medical team) at the scene of
an incident are generally the same what-
ever the hazard.  Moreover, many emer-
gency functions (e.g., direction and con-
trol,  communications,  and evacuation)
vary only slightly from hazard  to hazard.
Procedures to be followed for warning the
public of a hazardous materials incident,
for  example,  are not that different from
procedures followed in warning the public
about other incidents such  as a  flash
flood. It is possible, therefore, to avoid a
great deal  of  unnecessary  redundancy
and confusion by planning for all hazards
at the same time.   A multi-hazard EOP
avoids developing separate structures, re-
sources, and plans to deal with each type
of hazard.  Addressing the  general as-
pects of all hazards first and  then looking
at each potential hazard individually to see
if any unique aspects are involved result in
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efficiencies  and economies in the long
run.  Multi-hazard  EOPs also help ensure
that plans and systems are reasonably
compatible if a large-scale hazardous ma-
terials incident  requires a  simultaneous,
coordinated response by more than one
community or more than one level of gov-
ernment.

A community that does not have a multi-
hazard plan  is urged to consider seriously
the  advantages of  this integrated  ap-
proach to planning. In doing so, the com-
munity may want to  seek State govern-
ment advice and support.

CPG 1-8 describes a sample format, con-
tent,  and process for  State  and  local
EOPs.  It recommends that a multi-hazard
EOP include three components — a basic
plan, functional annexes, and hazard-spe-
cific appendices.    It encourages devel-
opment of a basic  plan that includes ge-
neric functional annexes applicable to any
emergency situation,  with unique aspects
of a particular hazard being addressed in
hazard-specific  appendices.   It stresses
improving the  capabilities  for simultane-
ous, coordinated response  by  a number
of emergency organizations at various lev-
els  of  government.  Local communities
that receive FEMA funds must incorporate
hazardous  materials  planning  into  their
multi-hazard EOP.  In most of these com-
munities, there are paid staff to do emer-
gency operations planning as well as re-
lated emergency management tasks.

CPG 1-8 provides flexible guidance, rec-
ognizing that substantial variation in plan-
 ning may exist from community to com-
 munity.  A  community  may develop  a
 separate hazardous material appendix to
 each functional  annex where there is  a
 need to reflect  considerations unique to
 hazardous  materials not adequately cov-
 ered in the functional annex. On the other
 hand,  a community may develop a single
 hazardous materials appendix to the EOP,
 incorporating all  functional annex consid-
 erations related to hazardous materials in
 one document.  The sample plan format
 used in CPG 1-8 is a  good one, but it is
 not the only satisfactory one.  It is likely
 that no one format is the best for all com-
 munities of all sizes  in all parts of  the
 country. Planners should,  therefore, use
 good judgment and common sense in ap-
 plying  CPG  1-8  principles to meet their
 needs.  The community has latitude in for-
 matting the plan  but should closely follow
 the basic content described in CPG 1-8.

 CPG 1-8 should  be used in preparing  the
 basic plan and functional annexes.  This
 guide should be  used as a supplement to
 CPG 1 -8 to incorporate hazardous materi-
 als considerations into a multi-hazard
 EOP.  Communities that want to  develop
 Standard  Operating  Procedures  (SOP)
 manuals could begin with  information in-
 cluded  in the functional  annexes of a
 multi-hazard EOP.

 A community that is incorporating hazard-
 ous  materials into a  multi-hazard  EOP
 should turn to Chapter  5 of  this guide for a
 discussion of those elements which need
 to be taken into account in  hazardous ma-
 terials  planning.
                 4.3  Single-Hazard Emergency Plan
If a  community  does not have  the re-
sources, time, or capability readily avail-
able to  undertake multi-hazard planning,
it may wish to produce a single-hazard
plan addressing hazardous materials.

Exhibit 4 identifies sections of an emer-
gency plan for hazardous  materials inci-
dents.    The  sample  outline is not  a
model.  It is not meant to constrain any
community.   Indeed,  each community
should seek  to  develop a plan that is
best suited to its own circumstances,
taking advantage of  the  sample outline
where appropriate.
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The type of plan envisioned in the sample
outline would affect all governmental and
private  organizations  involved in  emer-
gency response operations in a particular
community.  Its basic purpose would be to
provide the necessary data and documen-
tation to  anticipate and  coordinate the
many  persons and  organizations  that
would be involved in emergency response
actions.  As such, the plan envisioned in
this sample outline is intended neither  to
be a  "hip-pocket" emergency response
manual, nor to serve as a detailed Stan-
dard Operating Procedures (SOP) manual
for each of the many agencies and organi-
zations involved  in emergency response
actions,  although  it  could certainly be
used as a starting point for such manuals.
Agencies  that want to develop an  SOP
manual could begin with  the information
contained under  the appropriate function
in Plan Section C  of this sample outline. If
it is highly probable that  an  organization
will be involved in a hazardous materials
incident response, then a  more highly de-
tailed  SOP should be developed.
                                   Exhibit 4
  SAMPLE OUTLINE OF A HAZARDOUS MATERIALS  EMERGENCY PLAN
(NOTE:  Depending upon local circumstances, communities will develop some sections of
the plan more extensively than other sections.  See page 39 for how the sample outline
relates to SARA Title III requirements.)

A.  Introduction
   1.   Incident Information Summary
   2.   Promulgation Document
   3.   Legal Authority and Responsibility for Responding
   4.   Table of Contents
   5.   Abbreviations and Definitions
   6.   Assumptions/Planning Factors
   7.   Concept of Operations
       a.  Governing Principles
       b.  Organizational Roles and Responsibilities
       c.  Relationship to Other Plans
   8.   Instructions on Plan Use
       a.  Purpose
       b.  Plan Distribution
   9.   Record of Amendments
B.  Emergency Assistance Telephone Roster
C.  Response Functions*
   1.   Initial Notification of Response Agencies
   2.   Direction and Control


*These "Response Functions" are equivalent to the "functional annexes" of a multi-haz-
ard emergency operations plan described in CPG 1-8.
                            (continued on next page)
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                            Exhibit 4 (Continued)
  SAMPLE OUTLINE OF A HAZARDOUS MATERIALS EMERGENCY PLAN
   3.   Communications (among Responders)
   4.   Warning Systems and Emergency Public Notification
   5.   Public Information/Community Relations
   6.   Resource  Management
   7.   Health and Medical Services
   8.   Response Personnel Safety
   9.   Personal Protection of Citizens
       a.  Indoor Protection
       b.  Evacuation Procedures
       c.  Other  Public Protection Strategies
   10.   Fire and  Rescue
   11.   Law Enforcement
   12.   Ongoing  Incident Assessment
   13.   Human Services
   14.   Public Works
   15.   Others
D.  Containment and Cleanup
   1.   Techniques for Spill Containment and Cleanup
   2.   Resources for Cleanup and Disposal
E.  Documentation and Investigative Follow-up
F.  Procedures for Testing and Updating Plan
   1.   Testing the Plan
   2.   Updating the Plan
G.  Hazards Analysis (Summary)
H.  References
   1.   Laboratory, Consultant, and  Other Technical Support Resources
   2.   Technical  Library
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      5.  Hazardous Materials Planning  Elements
                              5.1  Introduction
This  chapter presents and  discusses  a
comprehensive list of planning  elements
related to hazardous materials incidents.
Communities that are developing  a haz-
ardous materials  appendix/plan need to
review these elements thoroughly.  Com-
munities  that are  revising an existing ap-
pendix/plan need to evaluate their present
appendix/plan  and identify what elements
need  to be  added, deleted, or  amended
in order to deal with the special problems
associated with the accidental spill or re-
lease of hazardous materials.

Title  III of  SARA requires  each emer-
gency plan  to include  at least each of
the following.  The  appropriate section
of the plan as indicated  in Exhibit  4  is
shown in  parentheses after   each re-
quired Title III plan element.

(1)    Identification of facilities  subject to
      the Title III requirements that are
      within  the emergency planning dis-
      trict; identification of routes likely to
      be  used for the  transportation of
      substances on  the list of extremely
      hazardous substances; and identifi-
      cation of additional facilities contrib-
      uting or subjected to additional risk
      due to their proximity to facilities,
      such as hospitals or natural gas fa-
      cilities.  (Exhibit 4, Sections A.6 and
      G)

(2)    Methods and procedures to be fol-
      lowed  by facility owners and opera-
      tors and local emergency and medi-
      cal personnel to respond to any re-
      leases of such substances. (Exhibit
      4, Section C)
(3)   Designation  of a community emer-
     gency coordinator and facility emer-
     gency coordinators, who shall make
     determinations necessary to imple-
     ment the plan.   (Exhibit 4,  Section
     A.7b)

(4)   Procedures  providing reliable,  ef-
     fective, and timely  notification by
     the facility emergency coordinators
     and the community emergency co-
     ordinator to persons designated in
     the  emergency  plan,  and to the
     public, that a release has occurred.
     (Exhibit 4, Sections C.1  and C.4)

(5)   Methods for determining the occur-
     rence of a release, and the area or
     population likely to be affected by
     such release.  (Exhibit 4,  Sections
     A.6 and G)

(6)   A description of emergency equip-
     ment and facilities in the community
     and at each facility in the commu-
     nity subject to Title III requirements,
     and an identification of the persons
     responsible for such equipment and
     facilities.  (Exhibit 4, Section C.6)

(7)   Evacuation  plans,   including provi-
     sions for a  precautionary evacu-
     ation and alternative traffic routes.
     (Exhibit 4, Section C.9b)

(8)   Training programs, including sched-
     ules for training of  local emergency
     response  and medical  personnel.
     (Exhibit 4, Sections C.6 and F.1)
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(9)    Methods and schedules for exercis-    pear in the sample outline for a hazardous
      ing the emergency plan. (Exhibit 4,    materials  emergency plan in Chapter 4.
      Section F.1)                         Community planners might choose, how-
                                         ever, to order these  planning elements
The various planning elements  are  dis-    differently in a multi-hazard plan following
cussed here in the same order as they ap-    the model of CPG 1-8.
                5.2  Discussion  of Planning Elements
The remainder of this chapter describes in detail what sorts of information could be in-
cluded in each element of the emergency plan. These issues need to be addressed in the
planning process.  In some cases, they will be adequately covered in SOPs and will not
need to be included in the emergency plan.
                      Planning Element A:  Introduction
          Planning Element A.1:  Incident Information Summary
D   Develop a format for recording essential information about the incident:
    •    Date and time
    •    Name  of person receiving call
    •    Name  and telephone number of on-scene contact
    •    Location
    •    Nearby populations
    •    Nature  (e.g., leak, explosion, spill,  fire,  derailment)
    •    Time of release
    •    Possible health effects/medical emergency information
    •    Number of dead or injured; where dead/injured  are taken
    •    Name  of material(s) released; if known
       o   Manifest/shipping invoice/billing  label
       o   Shipper/manufacturer identification
       o   Container type (e.g., truck,  rail car, pipeline, drum)
       o   Railcar/truck 4-digit identification numbers
       o   Placard/label information
    •    Characteristics of material (e.g., color,  smell, physical effects), only if readily
        detectable

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    •   Present physical state of the material (i.e.,  gas, liquid, solid)

    •   Total amount of material that may be released

    •   Other hazardous materials in area

    •   Amount of material released so far/duration of release

    •   Whether significant amounts of the  material appear to be entering the atmos-
        phere, nearby water, storm drains, or soil

    •   Direction, height,  color, odor of any vapor clouds  or plumes

    •   Weather conditions (wind direction and speed)

    •   Local terrain conditions

    •   Personnel at the scene

Comment:  Initial information is  critical.  Answers to some of  these questions may be
           unknown by the caller, but it is important to gather as much information as
           possible very quickly in order to facilitate decisions  on public notification and
           evacuation.  Some questions will apply to fixed facility incidents and others
           will apply only to transportation Incidents. Some questions will apply specifi-
           cally to air releases, while other questions will gather information about spills
           onto the ground or into water.  Identification numbers, shipping manifests,
           and placard  Information are essential to identify  any hazardous materials
           involved in transportation incidents, and to take initial precautionary and con-
           tainment steps.   First responders should use  DOT'S Emergency Response
           Guidebook to help identify hazardous materials.  Additional information about
           the identity and characteristics of chemicals is available by calling CHEMTREC
           (800-424-9300).   CHEMTREC and the  Hazard  Information Transmission
           (HIT) program are described in Appendix C.

           This emergency response notification section should be:

           BRIEF —  never more than  one page in  length.

           EASILY ACCESSIBLE — located on the cover or first  page of the  plan.  It
           should also be repeated  at least once inside the plan, in case the  cover Is
           torn off.

           SIMPLE — reporting information and emergency telephone numbers should
           be kept to a  minimum.

           Copies of the emergency response notification form could be provided to
           potential dischargers to familiarize them  with information  needed at  the time
           of an incident.
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              Planning Element A.2:  Promulgation Document

D   Statement of plan authority

Comment:  A letter,  signed by the community's chief executive, should indicate legal
           authority  and responsibility for putting the plan into action. To the extent that
           the execution of this plan involves various private and public-sector organiza-
           tions, it may be appropriate to include here letters  of agreement signed by
           officials of these organizations.
       Planning Element  A.3:  Legal Authority and Responsibility
                                 for Responding

D   Authorizing legislation and regulations

    •   Federal (e.g., CERCLA, SARA, Clean Water Act, National Contingency Plan, and
       Disaster Relief Act)

    •   State

    •   Regional

    •   Local

D   Mandated agency responsibilities

D   Letters of agreement

Comment:  If there are applicable laws regarding planning for response to  hazardous
           materials releases, list them here.  Analyze the basic authority of participat-
           ing agencies and summarize the results here.  The community may choose
           to enact legislation in support of its plan. Be  sure to identify any agencies
           required to respond to particular emergencies.
                 Planning Element A.4:  Table of Contents

Comment:  All sections of the plan should be listed here and clearly labeled with a tab for
           easy access.
           Planning Element A.5:  Abbreviations and  Definitions

Comment:  Frequently used abbreviations, acronyms, and definitions should be gathered
           here for easy reference.
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           Planning Element A.6:  Assumptions/Planning  Factors

D   Geography

    •   Sensitive environmental areas

    •   Land use (actual and potential, in accordance with local development codes)

    •   Water supplies

    •   Public transportation network (roads, trains, buses)

    •   Population density

    •   Particularly sensitive institutions (e.g., schools, hospitals, homes for the aged)

D  Climate/weather statistics

D  Time variables (e.g., rush hour, vacation season)

D  Particular characteristics of each facility and the transportation routes for which the
    plan is intended

    •   On-site details

    •   Neighboring population

    •   Surrounding terrain

    •   Known impediments (tunnels, bridges)

    •   Other areas at risk

D  Assumptions

Comment:  This section is a summary of precisely what local conditions make an emer-
           gency plan necessary. Information for this section will be derived from the
           hazards identification  and analysis. Appropiate maps should be included in
           this section. Maps should show: water intake, environmentally sensitive areas,
           major chemical manufacturing or storage facilities, population centers, and
           the location of response resources.

           Assumptions are the advance judgments concerning what would happen in
           the case of an accidental spill or release. For example, planners might as-
           sume that a certain percentage of local residents on  their own will evacuate
           the area along routes other than specified evacuation routes.
               Planning Element A.7:  Concept of Operations

Planning Element A.7a:  Governing Principles

Comment:  The plan should include brief statements of precisely what is expected to be
           accomplished if an incident should occur.
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Planning Element A.7b:  Organizational Roles and Responsibilities
D   Municipal government
    •    Chief elected official
    •    Emergency management director
    •    Community emergency coordinator (Title III of SARA)
    •    Communications personnel
    •    Fire service
    •    Law enforcement
    •    Public health agency
    •    Environmental agency
    •    Public works
D   County government
D   Officials of fixed facilities and/or transportation companies
    •    Facility emergency coordinators (Title III of SARA)
D   Nearby municipal and county governments
D   Indian tribes within  or nearby the affected jurisdiction
D   State government
    •    Environmental protection agency
    •    Emergency management agency
    •    Public health agency
    •    Transportation organization
    •    Public safety organization
D   Federal government
    •    EPA
    •    FEMA
    •    DOT
    •    HHS/ATSDR
    •    USCG
    •    DOL/OSHA


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    •   DOD

    •   DOE

    •   RRT

D    Predetermined arrangements

D    How to use outside resources

    •   Response capabilities

    •   Procedures for using outside resources

Comment:  This section lists all those organizations and officials who are responsible for
           planning and/or executing the pro-response (planning and prevention),  re-
           sponse  (implementing  the  plan  during an  incident),  and  post-response
            (cleanup and restoration) activities to a hazardous materials incident. One
           organization should be given command and control responsibility for each
           of these three phases of the emergency response. The role of each organi-
           zation/official should be clearly described.The plan should clearly designate
           who is in charge and should anticipate the potential involvement of State and
           Federal agencies and other response organizations.  (Note:  The above list of
           organizations and officials is not meant to be complete.  Each community will
           need to identify all the organizations/officials who are  involved in the local
           planning and response process.)

           This section of the plan should contain descriptions and information  on  the
           RRTs and the predesignated Federal OSC for the area covered by the plan.
            (See Section 1.4.1 of this guidance.) Because  of their distant location, it is
           often difficult  for  such organizations to reach a  scene  quickly;  planners
           should determine in advance approximately how much time would elapse  be-
           fore the Federal OSC could arrive at the scene.

           This section should also indicate where other disaster assistance can  be  ob-
           tained from Federal, State, or Regional sources.  Pre-arrangements can be
           made with higher-level government agencies,  bordering political  regions,
           and chemical plants.

           Major hazardous materials releases may overwhelm even the best prepared
           community, and an incident may even cross jurisdictional boundaries.  Coop-
           erative arrangements are an efficient means of  obtaining the additional per-
           sonnel, equipment, and materials that are needed in an emergency  by  re-
           ducing expenditures for maintaining extra or duplicative resources.  Any  co-
           ordination with outside agencies should be formalized through mutual aid and
           Good Samaritan  agreements  or  memoranda  of  understanding  specifying
           delegations of authority, responsibility, and duties.  These formal agreements
           can be included in the plan  if desired.
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Planning Element A.7c:  Relationship to Other Plans

Comment:  A major task  of the planning  group is to integrate planning for hazardous
           materials incidents  into already existing plans.  In  larger communities, it is
           probable that several emergency plans have been  prepared.  It is essential
           to coordinate these plans.  When more than one  plan is put into action si-
           multaneously, there is a real potential for confusion  among response person-
           nel unless the plans are carefully coordinated.  All emergency plans (includ-
           ing facility plans and hospital plans) that might be employed in the event of
           an accidental spill or release should be listed in this section. The community
           plan should include the methods and procedures to be followed  by facility
           owners and operators and local emergency response personnel to respond
           to any releases of such substances. The NCP, the Federal Regional contin-
           gency plan, any OSC plan for  the area, and any State plan should be refer-
           enced.   Of special  importance are all local emergency plans.

           Even where formal plans do not exist, various jurisdictions often have prepar-
           edness capabilities.  Planners  should seek information about informal agree-
           ments involving cities,  counties,  States, and countries.
              Planning Element A.8:  Instructions on Plan Use

Planning Element A.8a:  Purpose


Comment:  This should be a clear and succinct statement of when and how the plan is
           meant to be used.  It is appropriate to list those facilities and transportation
           routes explicitly considered in the plan.
Plan Section A.8b:  Plan Distribution

D   List of organizations/persons receiving plan

Comment:  The entire plan should be available to the public; it can be stored at a library,
           the local emergency management agency, or some other public place.  The
           plan should be distributed to all persons responsible for response operations.
           The plan distribution list should account for all organizations receiving such
           copies of the plan.  This  information is  essential when  determining  who
           should be sent revisions and updates to the plan.
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              Planning  Element A.9:  Record of Amendments

D   Change record sheet

    •    Date of change

    •    Recording signature

    •    Page numbers of  changes made

Comment:  Maintaining an up-to-date version of a plan is of prime importance.  When
           corrections, additions, or changes are made, they should be recorded in a
           simple  bookkeeping style so that all plan users will be aware that they are
           using a current plan.

           All that is necessary  for this page is  a set of columns indicating date of
           change, the signature of the person making the change, and the page num-
           ber for identifying each change made.
     Planning Element  B:  Emergency Assistance Telephone  Roster

D   List of telephone numbers for:

   •    Participating agencies

   •    Technical and response personnel

   •    CHEMTREC

   •    Public and private sector support groups

   •    National Response  Center

Comment:  An accurate and up-to-date  emergency  telephone roster is an essential
           item. The name of a contact person (and alternate) and the telephone num-
           ber  should be  listed.   Briefly  indicate the types  of expertise, services,  or
           equipment that each agency or group can provide. Indicate the times of day
           when the number will be answered; note all 24-hour telephone numbers.  All
           phone numbers and names of  personnel should be verified at least every  six
           months. When alternate numbers are available, these should be listed.  This
           section of the plan should stand alone so that copies can be carried by emer-
           gency response people and others. Examples of organizations for possible
           inclusion in a telephone roster  are as follows:
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                              Telephone Roster
Community Assistance
   Police
   Fire
   Emergency Management Agency
   Public Health Department
   Environmental Protection Agency
   Department of Transportation
   Public Works
   Water Supply
   Sanitation
   Port Authority
   Transit Authority
   Rescue Squad
   Ambulance
   Hospitals
   Utilities:
      Gas
      Phone
      Electricity
   Community Officials
      Mayor
      City Manager
   County Executive
   Councils of Government

Volunteer Groups
   Red Cross
   Salvation Army
   Church Groups
   Ham Radio Operators
   Off-Road Vehicle Clubs

State Assistance
   State Emergency Response Commission (Title
   State Environmental Protection Agency
   Emergency Management Agency
   Department of Transportation
   Police
   Public Health Department
   Department of Agriculture

Federal Assistance  (Consult Regional offices listed in Appendix F for appropriate tele-
            phone numbers.)
   Federal On-Scene Coordinator
   U.S. Department of Transportation
   U.S. Coast Guard
   U.S. Environmental Protection Agency
Response Personnel
   Incident Commander
   Agency Coordinators
   Response Team Members

Bordering Political Regions
   Municipalities
   Counties
   States
   Countries
   River Basin Authorities
   Irrigation Districts
   Interstate Compacts
   Regional Authorities
   Bordering International Authorities
   Sanitation Authorities/Commissions

Industry
   Transporters
   Chemical Producers/Consumers
   Spill Cooperatives
   Spill Response Teams
Media
   Television
   Newspaper
   Radio
 of SARA)
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   Federal Emergency Management Agency            24 hours
   U.S. Department of Agriculture
   Occupational Safety and Health  Administration
   Agency for Toxic Substances and Disease Registry   24 hours
   National Response Center
              24 hours
in Washington, DC area
                   or
   U.S. Army, Navy, Air Force
   Bomb Disposal and/or Explosive
       Ordnance Team, U.S. Army
   Nuclear Regulatory Commission                    24 hours
   U.S. Department of Energy
       Radiological Assistance                        24 hours
   U.S. Department of the Treasury
       Bureau of Alcohol, Tobacco, and Firearms

Other Emergency Assistance
   CHEMTREC                                      24 hours
   CHEMNET                                        24 hours
   CHLOREP                                        24 hours
   NACA Pesticide Safety Team                       24 hours
   Association of American Railroads/
       Bureau of Explosives                          24 hours
   Poison Control Center
   Cleanup Contractor
                           202-646-2400
404-452-4100
800-424-8802
202-426-2675
202-267-2675
                           301-951-0550

                           202-586-8100
                           800-424-9300
                           800-424-9300
                           800-424-9300
                           800-424-9300

                           202-639-2222
                  Planning Element C:  Response Functions

Comment:  Each function should be clearly marked with a tab so that it can be located
           quickly.  When revising and updating a plan, communities might decide to
           add, delete, or combine individual functions.
           Each response "function" usually includes several response activities. Some
           communities prepare a matrix that lists all response agencies down the left
           side of the page and  all  response  activities across the top of the page.
           Planners  can then  easily  determine which response  activities need inter-
           agency coordination and which,  if any, activities are not adequately provided
           for  in the plan.
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           Function 1:  Initial Notification of Response Agencies

D   24-hour emergency response hotline telephone numbers

    •     Local number to notify area public officials and response personnel

    •     Number to notify State authorities

    •     National Response Center (800-424-8802; 202-426-2675 or 202-267-2675 in
          Washington, DC area)

D   Other agencies  (with telephone  numbers) to  notify immediately  (e.g.,  hospitals,
    health department, Red Cross)

Comment:  The  local 24-hour emergency response hotline should be called first and
           therefore should have a prominent place in the plan.  Provision  should be
           made for notifying nearby municipalities and counties that could be affected
           by a vapor cloud  or liquid plumes in a water supply.

           Normally, the organization that operates the emergency response  hotline will
           inform other emergency service organizations (e.g., health department, hos-
           pitals, Red Cross) once the initial notification is  made.  The plan should pro-
           vide a method for notifying  all appropriate local, State, and Federal officials
           and  agencies, depending upon the severity of the incident. To ensure that
           the appropriate Federal On-Scene Coordinator  (OSC)  is notified of a spill or
           release, the NRC operated by the U.S. Coast Guard should be included  in the
           notification listing. CERCLA  requires that the NRC be notified by the responsi-
           ble party of releases of many hazardous materials in compliance with the
           reportable  quantity  (RQ)   provisions.   The  NRC  telephone number  is
           800-424-8802 (202-426-2675 or  202-267-2675  in  the  Washington, DC,
           area).  If there is  an  emergency notification number at the State or Regional
           level, it should be called before the NRC, and then a follow-up call made to
           the NRC  as soon  as  practicable.

           The  plan should indicate how volunteer and off-duty personnel will be sum-
           moned.  Similarly, there should be a method to notify special facilities  (e.g.,
           school districts, private schools, nursing homes, day care centers, indus-
           tries, detention  centers),  according to the  severity of the incident.
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                      Function 2:  Direction  and  Control

D   Name of on-scene authority

D   Chain of command (illustrated in a block diagram)
D   Criteria  for activating emergency operating center
D   Method  for establishing on-scene command post and communications  network for
    response team(s)
D   Method  for activating emergency response teams
D   List of priorities for response actions
D   Levels of response based on incident severity
Comment:   Response to a  hazardous materials spill or release will involve many partici-
            pants: police, firefighters, facility personnel, health personnel, and others.  It
            is also possible to have more than one organization perform the same serv-
            ice; for example, local police, the county sheriff and deputies, as well as the
            highway patrol  may respond to perform police functions. Because speed of
            response is so important, coordination is needed among the various agen-
            cies providing the same service.  It is essential to identify (by title or position)
            the one individual responsible for each  participating organization, and the one
            individual responsible for each major function and service.  The plan might
            require that the responsible person establish an Incident Command System
            (ICS).

            Work out,  in advance, the following:

            (1)  Who will be in charge  (lead organization)

            (2)  What will be the  chain of command

            (3)  Who will activate the emergency  operating center, if required

            (4)  Who will maintain the on-scene command post and keep it  secure

            (5)  Who will have advisory roles (and what their precise roles are)

            (6)  Who will make the technical  recommendations on response actions to
            the lead agency

            (7)  Who (if anyone)  will have veto power

            (8)  Who is responsible for requesting assistance from outside the commu-
            nity

            This chain  of command should be clearly illustrated in a block diagram.

            Response action checklists are a way of condensing much useful information.
            They are helpful for a  quick assessment of the response operation. If check-
            lists are used,  they should be prepared in sufficient detail to ensure that all
            crucial activities are included.
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         Planners should consider whether to have categories of response  actions
         based on severity.  The severity of an incident influences decisions on the
         level (or degree) of response to  be made.  This will determine how much
         equipment and how many personnel will be called, the extent of evacuation,
         and other factors.

         The following chart summarizes who and what are involved in three typical
         emergency conditions.  Information about the three response levels should
         be provided to special facilities (e.g., school districts, private schools, day
         care centers,  hospitals, nursing homes, industries, detention centers).
Response Level

I.   Potential
    Emergency
    Condition
II.  Limited
    Emergency
    Condition
III. Full
    Emergency
    Condition
       Description

An incident or threat of a
release which can be con-
trolled by the first response
agencies and does not require
evacuation of other than the
involved structure or the
immediate outdoor area.  The
incident is confined to a
small area and does not pose
an immediate threat to life or
property.

An incident involving a
greater hazard or larger area
which poses a potential
threat to  life or property
and which may require a
limited evacuation of the
surrounding area.
An incident involving a severe
hazard or a large area which
poses an extreme threat to
life and property and will
probably require a large scale
evacuation; or an incident
requiring the expertise or
resources of county, State,
Federal, or private agencies/
organizations.
    Contact:

Fire Department
Emergency Medical
  Services
Police Department
Partial EOC Staff
Public Information Office
CHEMTREC
National Response
  Center
All Agencies in
  Level I
HAZMAT Teams
EOC Staff
Public Works
  Department
Health Department
Red Cross
County Emergency
  Management Agency
State Police
Public Utilities

All Level I and II Agencies
  plus the following as
  needed:
Mutual Aid Fire, Police.
  Emergency Medical
State Emergency
  Management Agency
State Department of
  Environmental Resources
State Department of
  Health
EPA
USCG
ATSDR
FEMA
OSC/RRT
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            Function 3:  Communications (among Responders)

D   Any form(s) of exchanging information or ideas for emergency  response with other
    entities, either internal or external to the existing organizational structure.

Comment:  This aspect of coordination merits special consideration.  Different response
           organizations typically use different radio frequencies.  Therefore, specific
           provision must be made for accurate and efficient communication among all
           the various organizations during the response itself.  Several States have
           applied for one "on-scene"  command radio frequency that all communities
           can use. At a minimum, it may be beneficial to establish radio networks that
           will allow for communication among those performing similar  functions. The
           plan might specify who should be given  a radio unit, and who is allowed to
           speak on the radio. In order to avoid possible explosion/fire hazards, all com-
           munications equipment (including walkie-talkies) should  be intrinsically safe.
    Function 4:  Warning Systems and Emergency Public Notification

D   Method for alerting the public

    •    Title and telephone number of person responsible for alerting the public as soon
        as word of the \r\cldent is received

    •    List of essential data to be passed  on (e.g., health  hazards, precautions for
        personal protection, evacuation routes  and shelters, hospitals to be used)

Comment:   This section should contain precise information on how sirens or other signals
            will be used to alert the public in case of an emergency. This should include
            information on what the different signals mean, how to coordinate the use of
            sirens, and the geographic area covered by each siren. (If possible, a back-
            up procedure should  be identified.)  While a siren alerts those who hear it, an
            emergency broadcast is necessary  to provide detailed information about the
            emergency and what people should do.

            Sample Emergency Broadcast System  messages  should  be prepared with
            blank spaces that can be filled in with precise information about the accident.
            One sample message should provide fundamental information about the inci-
            dent and urge citizens to remain calm and await further information and in-
            structions.  Another sample message should  be for an evacuation. Another
            sample message should describe any necessary school evacuations so that
            parents will know where their children are.  Another sample message should
            be prepared to tell citizens to take shelter and inform them of other precau-
            tions they may take to protect themselves. The message should clearly iden-
            tify those areas in which protective actions are recommended, using familiar
            boundaries. Messages might be developed in languages other than English,
            if customarily spoken in the area.

            This section could be of urgent significance. When life-threatening materials
            are released, speed  of response is  crucial. It is not enough to have planned
            for alerting the community; one organization must be assigned the responsi-
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           bility of alerting the public as soon as word of the accidental release is re-
           ceived. Delay in alerting the public can lead to the loss of life.  In addition to
           sirens  and the Emergency Broadcast System, it may be necessary to use
           mobile public address systems and/or house-by-house contacts.  In this
           case, adequate protection must be provided for persons entering the area to
           provide such help.
           Function 5:  Public Information/Community Relations

D   Method to educate the public for possible emergencies

D   Method for keeping the public informed

    •    Provision for one person  to serve as  liaison to the public

    •    List of radio and T.V. contacts

Comment:  Many communities develop a public information program to educate citizens
           about safety  procedures  during an incident.  This program could include
           pamphlets; newspaper stories; periodic radio and television announcements;
           and programs for schools, hospitals, and homes for the aged.

           It is important to provide accurate information to the public in order to pre-
           vent panic.  Some citizens simply want to know what is happening.  Other
           citizens may need to  be prepared for possible evacuation or they may need
           to know what they can do immediately to protect themselves. Because infor-
           mation will be needed quickly, radio and television are much more important
           than newspapers in  most hazardous  materials releases.   In  less urgent
           cases, newspaper articles can provide detailed information to enhance public
           understanding  of accidental spills and procedures  for  containment  and
           cleanup.  One person should be  identified to serve as spokesperson.  It is
           strongly  recommended that the individual identified have training and experi-
           ence in public information, community relations, and/or media relations.  The
           spokesperson can identify for the media individuals who have specialized
           knowledge about the event.  The  chain of command should  include  this
           spokesperson.  Other members of the  response team should be trained to
           direct all communications and public relations issues to this one person.
                    Function 6:  Resource Management

D   List of personnel needed for emergency response

D   Training programs, including schedules for training of local emergency response and
    medical personnel

D   List of vehicles needed for emergency response

D   List of  equipment (both heavy  equipment and personal  protective  equipment)
    needed  for emergency response
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Comment:   This section should  list the resources  that will  be needed, and  where the
            equipment and vehicles are located or can be obtained.  A major  task in the
            planning process is to identify what resources are already available and what
            must still be provided.  For information on the selection of protective equip-
            ment, consult the Occupational Safety and Health Guidance Manual for Haz-
            ardous Waste Site Activities prepared by NIOSH, OSHA, USCG, and EPA; and
            the EPA/Los Alamos "Guidelines for the  Selection  of Chemical  Protective
            Clothing" distributed by the American Conference of Governmental Industrial
            Hygienists (Building B-7, 6500 Glynway Ave., Cincinnati, OH  45211).

            This section should also address funding for response equipment and per-
            sonnel.  Many localities are initially overwhelmed by the prospect of providing
            ample funding for hazardous materials response activities. In large localities,
            each response agency  is usually responsible for providing and maintaining
            certain equipment and personnel;  in such cases,  these  individual agencies
            must devise funding methods,  sources,  and accounting procedures.  In
            smaller localities with limited resources, officials frequently develop coopera-
            tive  agreements  with other jurisdictions  and/or private  industries.  Some
            communities stipulate in law that the party responsible for an incident should
            ultimately pay the cost of handling it.

            For a more detailed discussion of response training, consult Chapter 6 of this
            guide.
                       Function 7:  Health and Medical

D   Provisions for ambulance service

D   Provisions for medical treatment

Comment:  This section should indicate how medical personnel and emergency medical
           services can be summoned.  It may be appropriate to establish mutual aid
           agreements with nearby communities to provide backup emergency medical
           personnel and equipment. The community should determine a policy (e.g.,
           triage) for establishing priorities for the use of medical resources during an
           emergency. Medical  personnel must be made aware of significant chemical
           hazards in the community in order to train properly and prepare for possible
           incidents. Emergency medical teams and hospital personnel must be trained
           in proper methods for decontaminating and treating persons exposed to haz-
           ardous chemicals. Planners should include mental health specialists as part
           of the team assisting victims of serious incidents. Protective action recom-
           mendations for sanitation, water supplies, recovery, and reentry should be
           addressed  in this section.
                  Function 8:  Response Personnel Safety

D   Standard operating procedure for entering and leaving sites

D   Accountability for personnel entering and leaving the sites


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D   Decontamination procedures

D   Recommended safety and health equipment

D   Personal safety precautions

Comment:   Care must be taken  to choose equipment that protects the worker from the
            hazard present at the site without unnecessarily restricting the capacities of
            the worker.  Although the emphasis in equipment choices is commonly fo-
            cused on protecting  the  worker from the risks presented by the hazardous
            material, impaired vision, restricted movements, or  excessive heat can put
            the worker at equal risk.  After taking these factors into account, the planner
            should list the equipment appropriate to various degrees of hazard using the
            EPA Levels of Protection  (A, B, C, and D). The list should include: the type
            of respirator  (e.g., self-contained breathing apparatus, supplied air respira-
            tor, or air purifying respirator) if needed; the type of clothing that must be
            worn; and  the equipment needed to  protect the head, eyes,  face, ears,
            hands, arms, and feet.   This list can then be used as a base reference for
            emergency response.  The specific equipment used at a given site will vary
            according  to  the hazard.   In  addition, the  equipment  list  should be
            reevaluated and updated as more  information about the site is gathered to
            ensure that the appropriate equipment is being used.  Responders should
            receive ongoing training in the use of safety equipment.

            This section can also address liability related to immediate and long term
            health hazards to emergency responders. State and  local governments may
            want to consider insurance  coverage and/or the development of waivers for
            employees and contractors  who may be on site during a hazmat incident.
                Function 9:  Personal  Protection of Citizens

Function 9a:  Indoor Protection

D   Hazard-specific personal protection

Comment:  The  plan should clearly indicate what protective action should be taken in
           especially hazardous situations.  Evacuation is sometimes,  but not always,
           necessary.  (See Function 9b.)  For some hazardous materials it is safer to
           keep citizens inside with doors and windows closed rather than to evacuate
           them. It  is perhaps appropiate to go upstairs  (or downstairs).  Household
           items (e.g., wet towels) can provide  personal protection for some chemical
           hazards. Frequently a plume will move quickly past homes.  Modern housing
           has adequate air supply to allow residents to remain safely inside for an ex-
           tended period of time. Because  air circulation systems can  easily transport
           airborne toxic substances, a warning should be given to shut  off all air circu-
           lation systems (including heating, air conditioning, clothes  dryers, vent fans,
           and fire places)  both in private  and  institutional settings.

           In order for an indoor protective strategy to be effective,  planning and pre-
           paredness activities should  provide:
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                An emergency management system and decision-making criteria for
                determining when an indoor protection strategy should be used;

                A system for warning and advising the public;

                A system for determining when a cloud has cleared a particular area;

                A system for advising people to leave a building at an appropriate time;
                and

                Public education on the value of indoor protection and on expedient
                means to reduce ventilation.
Function 9b:  Evacuation Procedures

D   Title of person and alternate (s) who can order/recommend an evacuation

D   Vulnerable zones where evacuation could be necessary and a method for notifying
    these places

D   Provisions for a precautionary evacuation

D   Methods for controlling traffic flow and providing alternate traffic routes

D   Shelter locations and other provisions for evacuations (e.g.,  special assistance for
    hospitals)

D   Agreements with nearby jurisdictions to receive evacuees

D   Agreements with hospitals outside the local jurisdictions

D   Protective shelter for relocated populations

D   Reception and care of evacuees

D   Re-entry  procedures

Comment:   Evacuation  is the  most sweeping response to an accidental release.   The
            plan should clearly identify under what circumstances evacuation would be
            appropriate and necessary.  DOT'S Emergency Response Guidebook provides
            suggested distances for evacuating unprotected people from the scene of an
            incident during the initial phase. It is important to distinguish between general
            evacuation  of the  entire area and selective evacuation of a part  of the risk
            zone.  In either case, the plan should identify how people will be moved (i.e.,
            by city buses, police cars,  private vehicles).  Provision  must be made for
            quickly moving traffic out of the risk zone  and also for  preventing outside
            traffic from  entering the risk zone. If schools are located in the risk zone, the
            plan must identify  the location to which students will be moved in an evacu-
            ation and how parents will be notified of this location. Special attention must
            also be paid  to evacuating hospitals, nursing homes, and homes for the
            physically or mentally disabled.

            Maps  (drawn to the same  scale) with evacuation routes and alternatives
            clearly identified should be prepared for each risk zone in the area.  Maps
            should indicate precise routes to  another location where special populations
            (e.g., from schools,  hospitals, nursing homes, homes for the  physically or


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            mentally disabled) can be taken during an emergency evacuation, and the
            methods of transportation during the evacuation.

            Consideration of when and how evacuees will return to their homes should be
            part of this section.

            This section on evacuation should  include a description of how other agen-
            cies will coordinate with the medical community.

            Copies of evacuation procedures should be provided to all appropriate agen-
            cies and organizations (e.g., Salvation Army, churches, schools, hospitals)
            and could periodically be published in the local newspaper(s).
Function 9c:  Other Public Protection Strategies

D   Relocation

D   Water supply protection

D   Sewage system protection

Comment:   Some hazardous materials incidents may contaminate the soil or water of an
            area and pose a chronic threat to people living there. It may be necessary
            for people to move out of the area for a substantial period of time until the
            area is  decontaminated or until natural weathering or decay reduce the haz-
            ard. Planning must provide for the quick identification of a threat to the drink-
            ing water supply, notification of the public and private system operators, and
            warning of the users.  Planners should also provide sewage system protec-
            tion.  A hazardous chemical entering the sewage system can cause serious
            and long-term damage.  It may be necessary to divert sewage, creating
            another public  health threat and environmental problems.
                        Function 10:  Fire and Rescue

D   Chain of command among firefighters

D   List of available support systems

D   List of all tasks for firefighters

Comment: This section lists all firefighting tasks, as well as the chain of command for
           firefighters. This chain of command is especially important if firefighters from
           more than one jurisdiction will be involved.  Planners should check to see if
           firefighting tasks and the chain of command are mandated by their State law.
           Firefighters should be trained in proper safety procedures when approaching
           a hazardous materials incident.  They should have copies  of DOT's Emer-
           gency Response  Guidebook and  know  how  to  find shipping  manifests in
           trucks, trains, and vessels. Specific information about protective equipment
           for firefighters should be included here.   (See Function  6, "Resource Man-
           agement, " and the Occupational Safety and Health Guidance Manual for Haz-
           ardous Waste Site Activities.)
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           This section should also identify any mutual aid or Good Samaritan agree-
           ments with neighboring fire departments, hazmat teams, and other support
           systems.
                       Function 11:  Law Enforcement

D   Chain of command for law enforcement officials

D   List of all tasks for law enforcement personnel

Comment:  This section lists all the tasks for law enforcement personnel during an emer-
           gency response.  Planners should check to see if specific law enforcement
           tasks are mandated by their State law.  Because major emergencies will usu-
           ally involve State, county, and local law enforcement personnel, and possibly
           the military, a  clear chain of command must  be  determined in advance.
           Because they are frequently first on scene, law enforcement officials should
           be trained in proper procedures for approaching a hazardous materials inci-
           dent.  They should have copies of DOT'S Emergency Response Guidebook
           and know how to find shipping manifests in trucks, trains, and vessels.  Spe-
           cific information about protective equipment for law enforcement officials
           should be included here.  (See Function 6, "Resource Management,"  and
           the Occupational  Safety and Health Guidance Manual for Hazardous  Waste
           Site Activities.)

           This section should include maps that indicate control points where  police
           officers should be stationed in order to expedite the movement of responders
           toward the scene  and of evacuees away from the scene, to restrict unneces-
           sary traffic from entering the scene,  and to control  the possible spread of
           contamination.
                Function 12:  Ongoing Incident Assessment

D   Field monitoring teams

D   Provision for environmental assessment,  biological monitoring, and contamination
    surveys

D   Food/water controls

Comment:  After the notification that a release has occurred, it is crucial to monitor the
           release and assess its impact,  both on and off site.  A detailed log of all
           sampling results should be maintained.  Health  officials should be kept in-
           formed of the situation.  Often the facility at which the release has occurred
           will have the  best equipment for this purpose.

           This section should describe who is responsible to monitor the size, concen-
           tration, and movement of  leaks, spills,  and releases, and how they will do
           their work.  Decisions  about response  personnel safety, citizen protection
           (whether indoor or through evacuation),  and the use of food and water in the
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           area will depend upon an accurate assessment of spill or plume movement
           and concentration.  Similarly, decisions about containment and cleanup de-
           pend upon monitoring data.
                       Function 13:  Human Services

D   List of agencies providing human services

D   List of human services tasks

Comment:  This section should coordinate the activities of organizations such as the Red
           Cross, Salvation Army, local church groups, and others that will help people
           during a hazardous materials emergency. These services are frequently per-
           formed by volunteers.  Advance coordination is essential to ensure the most
           efficient use of limited resources.
                         Function  14:  Public Works

D   List of all tasks for public works personnel

Comment:  This section lists all public works tasks during an emergency response.  Pub-
           lic works officials should also be familiar with Plan Section D ("Containment
           and Cleanup").
                            Function 15:  Others

Comment:  If the preceding list of functions does not adequately cover the various tasks
           to be performed during emergency responses, additional response functions
           can be developed.

              Planning Element D:  Containment and Cleanup

 Planning Element D.1:  Techniques for Spill Containment and Cleanup

D   Containment and mitigation actions

D   Cleanup methods

D   Restoration of the surrounding environment


Comment:  Local responders will typically emphasize the containment and stabilization of
           an incident; State regulatory agencies can focus on cleanup details. Federal



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           RRT agencies can provide assistance during the cleanup process.  It is the
           releaser's legal and financial responsibility to clean up and minimize the risk
           to the health of the general public and workers that are involved.  The Federal
           OSC or  other government officials  should monitor the responsible  party
           cleanup activities.

           A clear and succinct list of appropriate containment and cleanup counter-
           measures should be  prepared for each hazardous material  present in the
           community in significant quantities.  This section should be  coordinated with
           the section on  "Response  Personnel Safety"  so that  response teams are
           subjected to minimal danger.  Planners should concentrate on the techniques
           that are applicable to the hazardous materials and terrain  of their area. It
           may be helpful to include sketches and  details on how cleanup should occur
           for certain areas  where spills  are  more likely.

           It is important to determine  whether a fire should be extinguished or allowed
           to burn.  Water used  in firefighting could become contaminated and  then
           would need to be contained or possibly  treated.  In addition, some materials
           may be  water-reactive and pose a greater  hazard  when in contact  with
           water.  Some vapors may condense into pools of liquid that must be  con-
           tained and removed. Accumulated pools may be recovered with appropriate
           pumps, hoses, and storage containers.  Various foams may be used to re-
           duce vapor generation rates.  Water sprays or fog may be applied at down-
           wind points away from "cold"  pools to absorb vapors and/or accelerate  their
           dispersal in the atmosphere.  (Sprays and fog might not reduce an explosive
           atmosphere.)  Volatile liquids might be  diluted or neutralized.

           If a toxic vapor comes to the ground on crops, on playgrounds, in drinking
           water, or other places where humans are likely to be affected  by it, the  area
           should be tested for contamination.  Appropriate steps must be taken if ani-
           mals (including fish and birds) that may become part of the human  food
           chain are in contact with a hazardous material. It  is important to identify in
           advance what instruments and methods  can be used to  detect the material in
           question.

           Restoration of the area is a long-range project, but general restoration steps
           should appear in the plan.   Specific consideration should  be given to the
           mitigation of damages to the  environment.
       Planning Element D.2:  Resources for  Cleanup and Disposal

D   Cleanup/disposal contractors and services provided

D   Cleanup material and equipment

D   Communications equipment

D   Provision for long-term site control during extended cleanups

D   Emergency transportation  (e.g., aircraft,  four-wheel-drive vehicles, boats)

D   Cleanup personnel



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D   Personal protective equipment

D   Approved disposal sites

Comment:  This section is similar to the yellow pages of the telephone book.  It provides
           plan users with the following important information:

           •    What types of resources are available (public and private);

           •    How much is stockpiled;

           •    Where it is located (address and telephone number); and

           •    What steps are necessary to obtain the resources.

           Organizations that may have resources for use during a hazardous materials
           incident include:

           •    Public agencies (e.g., fire, police, public works, public  health, agricul-
                ture,  fish and game);

           •    Industry (e.g., chemical producers, transporters, storers, associations;
                spill cleanup contractors; construction companies);

           •    Spill/equipment cooperatives;  and

           •    Volunteer groups (ham radio operators, four-wheel-drive vehicle
                clubs).

           Resource  availability will change with time, so keep this section of the plan
           up-to-date.

           Hazardous materials disposal may exceed the capabilities of  smaller cities
           and towns; in such cases, the plan should indicate the appropriate State and/
           or Federal agency that is  responsible for  making decisions regarding dis-
           posal.

           Disposal of hazardous materials or wastes is controlled by a  number of Fed-
           eral and State laws and regulations. Both CERCLA and RCRA regulate waste
           disposal and it is important  that this section reflect the requirements of these
           regulations for on-site disposal, transportation, and  off-site disposal.  The
           plan should include an updated list of RCRA disposal facilities for possible use
           during  an  incident.

           Many States have their own regulations regarding  transport and ultimate dis-
           posal of hazardous waste.  Usually such regulations are similar and substan-
           tially equal to Federal regulations.  Contact appropriate State agency offices
           for information on State requirements for hazardous  waste disposal.
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      Planning Element E:  Documentation and Investigative Follow-Up

n   List of required reports

D   Reasons for requiring the reports

D   Format for reports

D   Methods for determining whether the response mechanism worked properly

D   Provision for cost recovery

Comment:  This section indicates what information should be gathered about the release
           and the response operation.  Key response personnel could be instructed to
           maintain an accurate log of their activities.  Actual response costs should be
           documented in order to facilitate cost recovery.

           It is also important to identify who is responsible for the post-incident investi-
           gation to discover quickly the exact circumstances and cause of the release.
           Critiques of real incidents, if handled tactfully, allow improvements  to be
           made based on actual experience.  The  documentation described  above
           should help this  investigation determine if  response operations were  effec-
           tive, whether the emergency plan should  be amended,  and what follow-up
           responder  and public training programs are needed.
      Planning Element F:  Procedures for Testing and Updating Plan

                  Planning Element F.1:  Testing the Plan

D   Provision for regular tabletop, functional, and full-scale exercises

Comment:  Exercises or drills are important tools in keeping  a  plan functionally up-to-
           date.  These are simulated accidental releases where emergency response
           personnel act out their duties.  The exercises can  be  tabletop and/or they
           can be realistic enough so that equipment is deployed,  communication gear
           is tested, and "victims" are sent to hospitals with simulated injuries.  Plan-
           ners should  work with local industry and the private medical community when
           conducting simulation exercises, and they should provide for drills that com-
           ply with State  and local legal requirements concerning  the content and fre-
           quency of drills. After the plan is tested, it should  be  revised and retested
           until the planning team is confident that the plan is ready. The public should
           be involved in or at least informed of these exercises. FEMA, EPA, and CMA
           provide guidance on simulation exercises through  their training programs
           complementing this guide.

           This  section should specify:

           (1) The organization in charge of the exercise;

           (2) The types of exercises;
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            (3)  The frequency of exercises; and

            (4)  A procedure for evaluating performance, making changes to plans, and
                correcting identified deficiencies in response capabilities as necessary.
                (See Chapter 6 of this guide.)
                 Planning Element F.2:  Updating the Plan

D   Title and organization of responsible person (s)

D   Change notification procedures

D   How often the plan should be audited and what mechanisms will be used to change
    the plan

Comment:   Responsibility should be delegated to someone to make sure that the plan is
            updated frequently and that all  plan holders are informed of the changes.
            Notification of changes should  be by written  memorandum  or  letter; the
            changes should be recorded in  the RECORD OF AMENDMENTS page at the
            front of the completed plan. Changes should be consecutively numbered for
            ease  of tracking and accounting.

            Following are examples of  information that must regularly be checked for
            accuracy:

            (1) Identity and phone numbers of response personnel

            (2) Name,  quantity, properties,  and location of  hazardous materials in the
            community.  (If new hazardous  materials are made, used, stored, or trans-
            ported in the community, revise the plan as needed.)

            (3) Facility maps

            (4) Transportation routes

            (5) Emergency services  available

            (6) Resource availability

            This topic is considered in greater detail in Chapter 6  of this guidance.
             Planning Element G:  Hazards Analysis (Summary)

D   Identification of hazards

D   Analysis of vulnerability

D   Analysis of risk

Comment:  This analysis is a crucial aspect of the planning process.  It consists of deter-
           mining where hazards are likely to exist, what places would most likely be
           adversely affected,  what hazardous materials could  be involved, and  what
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            conditions might exist during a spill or release.  To prepare a hazards analy-
            sis, consult Chapter 3 of this guide, EPA's CEPP technical  guidance, and
            DOT'S Community  Teamwork  and Lessons Learned.  Ask Federal  offices
            (listed in Appendix F) for information about available computer programs to
            assist in a hazards  analysis.

            Individual data sheets and maps for each facility and transportation routes of
            interest could be included in this section.  Similar data could be included for
            recurrent shipments of hazardous materials through the area. This section
            will also assess the probability of damage and/or injury. In communities with a
            great deal of hazardous  materials activity,  the hazards analysis will  be too
            massive to include in the  emergency plan.  In that case, all  significant details
            should be summarized here.
                       Planning Element H:  References

               Planning Element  H.1:   Laboratory, Consultant,
                  and Other Technical Support Resources

D  Telephone directory of technical support services

    •   Laboratories (environmental and public health)

    •   Private consultants

    •   Colleges or universities (chemistry  departments and special courses)

    •   Local chemical  plants


Comment:  This section should identify the various groups capable of providing technical
           support and the specific person to be contacted. Medical and environmental
           laboratory resources to assess the  impact of the most probable  materials
           that could be released should be identified.  Note should be made about the
           ability of these laboratories to provide rapid analysis. These technical experts
           can provide advice during a disaster and also be of great service during the
           development of this plan.  For this  reason, one of the first planning steps
           should be gathering information for this section.
                  Planning Element H.2:  Technical Library

D   List of references, their location, and their availablility

    •    General planning references

    •    Specific references for hazardous materials

    •    Technical references and methods for using national data bases

    •    Maps



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Comment:   Industry sources can provide many specific publications dealing with hazard-
            ous materials.  This section of the plan will list those published resources that
            are actually available in the community.  Also list any maps (e.g., of facili-
            ties, transportation routes) that will aid in the response to an accidental spill
            or  release.

            The list of technical references in Appendix E could be helpful.  Regional Fed-
            eral offices  can also be contacted (see Appendix F).

            It is important for planners to acquire, understand, and be able to use avail-
            able hazardous materials data bases, including electronic data bases avail-
            able from commercial and government sources.  Planning guides such as
            DOT'S Community Teamwork, CMA's CAER program, EPA's CEPP technical
            guidance, and this guide  should also be available locally.
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       6.  Plan Appraisal  and Continuing Planning
                             6.1  Introduction
Any emergency plan must be evaluated
and kept up-to-date through the review
of  actual  responses,  simulation  exer-
cises,  and regular  collection of  new
data. Effective emergency preparedness
requires  periodic review and  evaluation,
and the  necessary  effort  must be  sus-
tained  at the community  level.   Plans
should reflect any recent changes in: the
economy, land use, permit waivers,  avail-
able technology,  response  capabilities,
hazardous materials present, Federal and
State laws,  local laws and  ordinances,
road configurations,  population  change,
emergency telephone numbers, and facil-
ity location.  This chapter describes key
aspects of appraisal and provides specific
guidance for maintaining an updated haz-
ardous materials emergency plan.
                    6.2  Plan Review and Approval
Plan review and approval are critically im-
portant  responsibilities of  the  planning
team.  This section discusses the various
means by which a plan can be reviewed
thoroughly and systematically.

6.2.1.  Internal Review
The planning team, after drafting the plan,
should conduct an internal review of the
plan.   It  is not sufficient  merely  to read
over the  plan for clarity or to  search for
errors. The plan should also be assessed
for adequacy and completeness.  Appen-
dix D is an adaptation of criteria developed
by the National Response Team  that  in-
cludes questions  useful  in  appraising
emergency  plans.   Individual  planning
team  members can use these questions
to conduct self review of their own work
and the team can assign  a committee to
review the total plan. In the case of a haz-
ardous materials  appendix  (or appendi-
ces) to a multi-hazard EOP, the team will
have to review the basic  EOP as well as
the functional annexes to obtain an overall
assessment of content.  Once the team
accomplishes this internal review the plan
should be revised in preparation for exter-
nal review.

6.2.2.  External Review
External review legitimizes the  authority
and fosters community acceptance of the
plan.  The review process should involve
elements of peer review, upper level re-
view, and community input. The planning
team must devise a process to receive,
review, and  respond  to  comments from
external reviewers.

^ A. Peer Review

Peer review entails finding  qualified indi-
viduals who can provide objective reviews
of the plan.  Individuals with qualifications
similar  to those considered  for inclusion
on the  planning team should be selected
as peer reviewers.  Examples of appropri-
ate individuals include:
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     D   The safety or environmental en-
         gineer in a local industry;
     D   Responsible   authorities   from
         other political jurisdictions (e.g.,
         fire chief, police,  environmental
         and/or health officers);
     D   A local college professor familiar
         with  hazardous   materials  re-
         sponse operations; and
     D   A  concerned  citizen's  group,
         such as the League  of Women
         Voters, that provides a high level
         of  objectivity along with the ap-
         propriate environmental  aware-
         ness.
Exhibit 2  (Chapter 2, page 13)  presents a
comprehensive list of potential peer re-
viewers.  Those selected as peer  review-
ers should use the criteria contained in
Appendix D to develop their assessments
of the plan.

^ 6. Upper Level Review

Upper level review involves  submitting the
plan to an individual  or  group with over-
sight authority  or responsibility for  the
plan.  Upper level  review should take
place after peer review  and modification
of the plan.

^ C. Community Input

Community involvement is vital to success
throughout the planning  process.   At the
plan appraisal stage, such involvement
greatly facilitates  formal acceptance of
the plan by  the community. Approaches
that can be  used include:

     D   Community   workshops  with
         short presentations by planning
         team members followed by  a
         question-and-answer period;
     D   Publication of notice "for com-
         ment" in local newspapers, of-
         fering interested individuals  and
         groups an opportunity to express
         their views in writing;
     D   Public  meetings  at  which  citi-
         zens can submit oral and written
         comments;
     D   Invited reviews by key  interest
         groups that provide an opportu-
         nity for direct  participation  for
         such groups that are not repre-
         sented on  the planning team;
         and
     D   Advisory councils composed of
         a relatively  large number of in-
         terested parties that can  inde-
         pendently review and  comment
         on the planning team's efforts.
These activities do more than encourage
community consensus building.  Commu-
nity outreach at this stage in the process
also improves the soundness of the plan
by  increased  public  input  and expands
public understanding  of the plan and thus
the effectiveness of  the emergency  re-
sponse to a hazardous materials incident.

^ D. State/Federal Review

After local review and testing through  ex-
ercises,  a community  may want to  re-
quest review of the plan by State and/or
Federal  officials.  Such  a review  will de-
pend upon  the availability  of  staff  re-
sources.  Planning committees set up in
accordance with Title III  of SARA are to
submit a copy of the emergency  plan to
the State emergency response commis-
sion for review to ensure coordination of
the plan with  emergency plans of other
planning  districts.  Federal Regional Re-
sponse Teams may review and  comment
upon an  emergency  plan, at the  request
of a local emergency planning committee.
FEMA  Regional offices review  FEMA-
funded multi-hazard EOPs using criteria in
CPG 1-8A.

6.2.3.  Plan Approval
The planning  team  should  identify  and
comply  with  any local or State require-
ments for formal plan approval.  It  may be
necessary for local officials to enact legis-
lation that gives legal recognition to the
emergency plan.
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                   6.3   Keeping the  Plan Up-to-Date
All  emergency  plans  become  outdated
because of social, economic,  and envi-
ronmental  changes.   Keeping  the  plan
current  is  a difficult task,  but can be
achieved by scheduling reviews regularly.
As  noted in Chapter  5,  the  plan itself
should  indicate  who is  responsible  for
keeping it up-to-date.  Outdated informa-
tion should  be replaced, and the results of
appraisal exercises  should  be  incorpo-
rated into the plan.  The following tech-
niques will aid in keeping abreast of rele-
vant changes:

     D   Establish  a regular review  pe-
         riod,   preferably   every   six
         months,  but  at  least  annually.
         (Title III of SARA requires an an-
         nual review.)

     D   Test the  plan  through  regularly
         scheduled  exercises   (at least
         annually). This testing should in-
         clude  debriefing after the exer-
         cises whenever gaps in prepar-
         edness and response capabili-
         ties are identified.

     D   Publish a notice and announce a
         comment period for plan review
         and revisions.

     D   Maintain  a  list  of individuals,
         agencies, and organizations that
         will be  interested in participating
         in the review process.

     D   Make  one  reliable organization
         responsible for coordination  of
         the    review    and     overall
         stewardship of the  plan.  Use of
         the planning team  in this role is
         recommended,  but may  not be
         a  viable option due to time avail-
         ability constraints of team mem-
         bers.

     D   Require immediate reporting by
         any facility of  an  increase  in
         quantities of hazardous materi-
         als dealt with in the emergency
         plan, and require review and re-
         vision  of  plan  if  needed in  re-
         sponse to such new information.

    D    Include a  "Record  of  Amend-
         ments  and  Changes"  sheet  in
         the front section of the plan  to
         help  users  of the  plan stay
         abreast of all plan modifications.

    D    Include a "When and Where  to
         Report  Changes"  notice in the
         plan and a request for holders of
         the plan to report  any  changes
         or suggested revisions to the re-
         sponsible organization at the ap-
         propriate time.

    D    Make  any sections  of  the plan
         that  are  subject  to  frequent
         changes  either easily  replace-
         able  (e.g., looseleaf,  separate
         appendix),  or  provide blank
         space (double- or triple-spaced
         typing) so that old  material may
         be crossed  out  and new data
         easily written  in.   This applies
         particularly to telephone rosters
         and  resource and  equipment
         listings.

The  organization responsible  for review
should  do the following:

    D    Maintain a list of plan  holders,
         based on the original distribution
         list,  plus any new  copies made
         or distributed.  It is advisable to
         send out a periodic  request  to
         departments/branches  showing
         who is on the distribution list and
         asking for any additions or cor-
         rections.

    D    Check  all  telephone numbers,
         persons named  with particular
         responsibilities,  and  equipment
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         locations and availability. In ad-
         dition,   ask  departments  and
         agencies to review sections of
         the plan defining their responsi-
         bilities and  actions.

     D   Distribute  changes.    Changes
         should  be  consecutively  num-
         bered for ease of tracking.  Be
         specific, e.g.,  "Replace page	
         with  the  attached   new  page
         	.," or " Cross out	on page
         	 and  write  in the following"
         (new phone number, name, lo-
         cation,  etc.).   Any  key change
         (new emergency phone number,
         change in equipment availability,
         etc.) should  be distributed as
         soon as it occurs.   Do  not wait
         for the regular review period to
         notify plan holders.

     D   If possible,  the use of electronic
         word  processing   is   recom-
         mended  because  it  facilitates
         changing the plan.  After a sig-
         nificant  number  of  individual
         changes, the entire plan should
         be redistributed to ensure  com-
         pleteness.

    D   If practical, request an acknow-
         ledgement   of  changes  from
         those   who   have    received
         changes.  The  best  way to do
         this  is   to  include   a  self-
         addressed  postcard  to be  re-
         turned   with  acknowledgement
         (e.g., "I have received and en-
         tered changes dated _ . Signed
    D   Attend  any plan critique meet-
         ings and  issue changes as may
         be required.

    D   Integrate  changes with  other re-
         lated plans.
                         6.4  Continuing  Planning
In addition to the  periodic updates  de-
scribed  above,  exercises, incident  re-
views, and training are necessary to  en-
sure current and effective planning.

6.4.1   Exercises
The plan should also be evaluated through
exercises to see if its required activities
are effective in practice and if  the evalu-
ation  would reveal more efficient ways of
responding to  a  real emergency.   As
noted in Chapter 5, the plan itself should
indicate who is responsible for conducting
exercises.  Simulations can be  full-scale,
functional, or tabletop exercises.

A  full-scale exercise  is a mock emer-
gency in which the response organizations
that would be involved in an actual emer-
gency perform  the actions they would
take in the emergency. These simulations
may focus on  limited  objectives (e.g.,
testing the capability of local hospitals to
handle relocation problems). The respon-
sible  environmental,  public  safety,  and
health agencies simulate, as realistically
as possible, notification, hazards identifi-
cation and analysis,  command structure,
command post staging, communications,
health care,  containment,  evacuation  of
affected areas, cleanup, and documenta-
tion.  Responders use the protective gear,
radios, and response equipment and act
as they would in a real  incident.  These
multi-agency exercises provide a clearer
understanding of the roles and resources
of each responder.

A  functional exercise involves  testing  or
evaluating  the capability of individual  or
multiple functions, or activities within a
function.

A  low-cost, valuable  version of an exer-
cise is the  staging of a tabletop exercise.
In  this exercise,  each agency representa-
tive describes and acts out what he or she
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would do at each step of the response un-
der the circumstances given.

Exercises are most beneficial  when  fol-
lowed by a meeting of all participants to
critique the performance of those involved
and the strengths and weaknesses of the
plan's operation. The use of an outside
reviewer, free of local biases,  is desir-
able.    The emergency plan  should be
amended   according   to  the   lessons
learned.  Provisions should  be made to
follow up exercises  to  see that identified
deficiencies are  corrected.

Communities  that want  help in preparing
and conducting  exercises should consult
FEMA's four-volume  "Exercise  Design
Course," which  includes sample  hazard-
ous materials exercises.  CMA's Commu-
nity Emergency Response Exercise Hand-
book is  also helpful.  CMA describes four
types of exercises:  tabletop, emergency
operations simulation, drill, and field exer-
cise.

6.4.2  Incident Review
When a hazardous materials incident does
occur,  a review or critique of the  incident
is a means of evaluating the plan's effec-
tiveness. Recommendations for conduct-
ing an incident review are:

    D   Assign  responsibility for  incident
        review  to the  same organization
        that is  responsible for plan  up-
        date, for example,  the planning
        team.

    D   Conduct the  review only after
        the emergency is under control
        and sufficient time has passed to
        allow emergency respondents to
        be objective about the incident.

    D   Use  questionnaires,  telephone
        interviews,  or  personal  inter-
        views to obtain comments and
        suggestions from emergency re-
        spondents.  Follow-up on non-
        respondents.

    n   Identify plan and response defi-
        ciencies: items that were  over-
         looked, improperly identified, or
         were not  effective.

     D   Convene  the planning  team to
         review comments and make ap-
         propriate  plan changes.

     D   Revise  the plan  as necessary.
         Communicate  personal  or de-
         partmental   deficiencies   infor-
         mally to the appropriate person
         or department. Follow up to see
         that deficiencies are corrected.

6.4.3 Training
Training courses can help  with continuing
planning  by sharpening response person-
nel  skills, presenting up-to-date ideas/
techniques,  and promoting contact with
other people involved  in emergency re-
sponse.  Everyone who occupies a  posi-
tion that is identified in the plan must have
appropriate training.  This  applies to per-
sons at all levels who serve to coordinate
or have  responsibilities under the  plan,
both those directly and indirectly involved
at the scene of an incident.  One should
not  assume that a  physician in the emer-
gency room or a professional environmen-
talist is specifically trained  to perform his/
her  assigned  mission  during an emer-
gency.

The training  could  be a short  briefing on
specific  roles and  responsibilities,  or  a
seminar  on  the plan or  on emergency
planning  and response in general.   How-
ever the training is conducted, it should
convey a full appreciation  of  the impor-
tance of each role  and the  effect that
each person  has on implementing an ef-
fective emergency response.

Training  is available  from  a  variety of
sources in the public and private sectors.
At the Federal level, EPA,  FEMA, OSHA,
DOT/RSPA and the USCG offer hazardous
materials training.  (In some cases,  there
are  limits  on   attendance  in  these
courses.)  FEMA,  EPA, and  other NRT
agencies  cooperatively offer  the  inter-
agency  "train-the-trainer"  course,  Haz-
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ardous Materials Contingency Planning, at
Emmitsburg, MD and in the field.

Title III of SARA authorizes Federal funding
for training.  Communities seeking training
assistance  should  consult  appropriate
State agencies. States may consult with
the RRT and the various Federal Regional
and  district  offices.  (See Appendix F.)

In  addition to government agencies, con-
sult  universities or  community  colleges
(especially  any fire  science  curriculum
courses), industry associations, special
interest groups, and the  private  sector
(fixed facilities, shippers,  and  carriers).
Many training films and slide presentations
can  be borrowed or rented at little cost.
Many chemical companies and carriers
provide some level of training free.

The  Chemical Manufacturers Association
has a lending library of audio-visual train-
ing aids for use by personnel who respond
to  emergencies involving chemicals.  The
training aids are available  on a loan basis
at  no charge to emergency response per-
sonnel and the public sector.

Training aids can also be purchased from:

National Chemical  Response and
   Information Center
Chemical  Manufacturers Association
2501  M Street, N.W.
Washington, DC 20037
In  addition  to  classroom  training,  re-
sponse personnel will need hands-on ex-
perience with equipment to be used dur-
ing an emergency.

Communities should provide for refresher
training of response personnel.  It is not
sufficient to  attend training  only once.
Training must be carried out on a continu-
ing basis to ensure  currency and capabil-
ity.  Some communities have found it ef-
fective to hold this refresher training in
conjunction with an  exercise.

The NRT, through its member agencies, is
developing  a strategy  to  address issues
related to emergency  preparedness and
response  for  hazardous  materials  inci-
dents. The training  strategy includes:  (1)
improved coordination of available Federal
training programs and  courses; (2) shar-
ing information  about  available training,
and lessons learned from responses to re-
cent  hazardous materials incidents;  (3)
the increased use of exercises as a train-
ing method;  (4) the revision  of  existing
core  courses,  and  the  development  of
any needed new core courses that  pre-
pare responders to do the actual tasks ex-
pected in their own  communities;  and (5)
decentralizing  the delivery of  training  so
that it is more easily available to respond-
ers.  Further information about this train-
ing strategy can be  obtained from  EPA or
FEMA  offices  in Washington, DC  (see
page F-1 for addresses).
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                                APPENDIX A
     IMPLEMENTING  TITLE III:  EMERGENCY PLANNING  AND
                   COMMUNITY RIGHT-TO-KNOW:

      SUPERFUND AMENDMENTS AND REAUTHORIZATION
                               ACT OF  1986
  This appendix includes a detailed sum-
  mary of Title HI of SARA.  The material
  printed in italics indicates how informa-
  tion generated by compliance with Title
  III can  be of  use  to local emergency
  planning committees.  Exhibit 5 is a list
  of key dates relative to Title III imple-
  mentation.  Exhibit 6 is a graphic repre-
  sentation of the flow of information re-
  quired by Title III.  Exhibit 7 summa-
  rizes ways in which Title III information
  can be used by local emergency planning
  committees.  Exhibit 8 identifies various
  lists of chemicals mentioned in Title III
  and indicates  the  purpose (s) of each
  list.
On  October  17,  1986,  the President
signed the "Superfund Amendments and
Reauthorization Act of 1986" (SARA) into
law.  One part of the new SARA provisions
is Title III:  the "Emergency Planning and
Community Right-to-Know Act of  1986."
Title  III establishes requirements for Fed-
eral, State, and local governments, and
Industry  regarding  emergency planning
and  community right-to-know  reporting
on hazardous chemicals.  This legislation
builds upon the Environmental Protection
Agency's  (EPA's) Chemical  Emergency
Preparedness Program  (CEPP) and  nu-
merous  State and local programs aimed
at helping communities  to meet their re-
sponsibilities in regard to potential chemi-
cal emergencies.

Title  III has four major  sections:  emer-
gency planning (§ 301-303),  emergency
notification  (§ 304),  community right-to-
know reporting  requirements  (§ 311,
312), and toxic chemical release reporting
— emissions inventory (§ 313).  The sec-
tions are interrelated in a way that unifies
the emergency  planning and community
right-to-know provisions of Title III. (See
Exhibit 6.)
 In addition to increasing  the public's
 knowledge and access to information on
 the presence of hazardous  chemicals in
 their communities and releases of these
 chemicals into  the  environment, the
 community  right-to-know provisions of
 Title III will be  important  in preparing
 emergency plans.
This  appendix  includes  a  summary  of
these four major sections, followed by a
discussion of other Title III topics of Inter-
est to emergency planners.
Sections 301-303:  Emergency
 Planning

The emergency planning sections are de-
signed to develop State and local govern-
ment  emergency  preparedness  and re-
sponse capabilities through better coordi-
nation and planning, especially at the local
level.

Title III requires that the Governor of each
State  designate a State emergency re-
sponse commission  (SERC)  by April 17,
1987.   While existing State organizations
can be designated as the SERC, the com-
mission  should have broad-based  repre-
sentation.   Public agencies  and depart-
ments concerned  with issues  relating to
the  environment,   natural   resources,
emergency management, public health,
occupational safety, and transportation all
have important roles in Title III activities.
                                   Page A-1

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Various public  and private sector groups
and associations with interest and exper-
tise in Title III issues can also be  included
on  the SERC.

The SERC must  designate  local emer-
gency planning districts by July 17, 1987,
and appoint local  emergency  planning
committees (LEPCs) within one month af-
ter  a district is designated.  The  SERC is
responsible for supervising and coordinat-
ing  the activities of the  LEPCs, for estab-
lishing procedures for receiving and proc-
essing public requests for information col-
lected under other sections of Title III, and
for  reviewing local emergency plans.

The LEPC must include  elected State and
local officials, police, fire, civil defense,
public   health   professionals,    environ-
mental, hospital, and transportation offi-
cials as well  as representatives of facili-
ties, community groups, and the media.
Interested persons may petition the SERC
to modify the membership of an LEPC.

No  later than September 17,  1987, facili-
ties subject to the emergency planning re-
quirements must notify the LEPC of a rep-
resentative who will participate in the plan-
ning process as a facility emergency co-
ordinator.
 Facility emergency coordinators will be
 of great service to LEPCs.   For exam-
 ple,  they  can provide technical assis-
 tance, an understanding of facility  re-
 sponse procedures, information about
 chemicals and their potential effects on
 nearby persons  and  the environment,
 and   response  training  opportunities.
 CEPP experience revealed that, as a re-
 sult of CMA's CAER initiative, there al-
 ready exist  a large  number of plant
 managers  and other facility personnel
 who  want  to  cooperate with local com-
 munity planners.
 The LEPC must establish rules, give public
 notice of its activities, and establish pro-
 cedures for handling public  requests for
 information.

 The LEPC's  primary responsibility will be
 to develop  an emergency response plan
 by  October 17,  1988.  In developing this
 plan, the  local  committee will  evaluate
 available resources for preparing for and
 responding  to a potential chemical acci-
 dent.  The plan  must include:

  •   Identification  of  facilities  and  ex-
     tremely    hazardous   substances
     transportation routes;
     Emergency  response
     on site and off site;
procedures,
  •  Designation of a community coordi-
     nator and  facility  coordinator (s)  to
     implement  the plan;

  •  Emergency notification procedures;

  •  Methods for determining the occur-
     rence of a  release and the probable
     affected area and  population;

  •  Description of community and indus-
     try emergency equipment and facili-
     ties, and the identity of persons re-
     sponsible for them;

  •  Evacuation plans;

  •  Description and schedules of a train-
     ing   program  for  emergency  re-
     sponse to chemical  emergencies;
     and

  •  Methods and schedules for exercis-
     ing  emergency response plans.

To assist  the LEPC in preparing and re-
viewing plans, Congress required the Na-
tional Response  Team (NRT), composed
of 14  Federal agencies with emergency
preparedness and response  responsibili-
ties, to publish  guidance  on emergency
planning.  This Hazardous Materials Emer-
gency  Planning Guide is being published
by the NRT to fulfill this  requirement.
                                    Page A-2

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The emergency plan must be reviewed by
the SERC upon completion  and reviewed
annually by the LEPC.  The Regional Re-
sponse Teams (RRTs), composed of Fed-
eral Regional officials and State represen-
tatives, may review the plans and provide
assistance if the LEPC so requests.

The emergency planning activities of the
LEPC and  facilities should  initially be fo-
cused on,  but not limited to,  the ex-
tremely hazardous substances published
as an  interim  final rule in the November
17, 1986,  Federal Register.  The list in-
cluded  the threshold   planning  quantity
(TPQ)  for each substance.  EPA can re-
vise the list and TPQs  but must take into
account the toxicity,  reactivity,  volatility,
dispersability,  combustibility, or flamma-
bility  of  a substance.  Consult  EPA  Re-
gional  offices  for  a copy of the Title III
(Section 302)  list of extremely hazardous
substances.

Any facility that produces, uses,  or stores
any of the listed  chemicals in a quantity
greater than the TPQ must meet all emer-
gency planning requirements. In addition,
the SERC or the Governor  can designate
additional facilities, after public comment,
to be subject  to these requirements. By
May 17, 1987, facilities must  notify the
SERC  that they are subject to these re-
quirements.  If, after that time, a facility
first begins to produce, use, or store an
extremely  hazardous  substance  in an
amount exceeding the threshold planning
quantity, it must notify the SERC and LEPC
within 60 days.

Each  SERC must  notify EPA Regional of-
fices of all facilities subject to Title III plan-
ning requirements.
 In  order  to complete information on
 many sections of the emergency plan,
 the LEPC will require data from the fa-
 cilities covered under the plan. Title HI
 provides authority for the LEPC to se-
 cure from a facility information that it
 needs for emergency planning and re-
  sponse.  This is provided by Section 303
  (d)(3), which states that:

  "Upon request from the emergency plan-
  ning committee, the owner or operator
  of the facility shall promptly provide in-
 formation to such committee necessary
 for developing and implementing  the
  emergency plan."

  Within the trade secret restrictions con-
  tained in Section 322, LEPCs should be
  able to use this authority to secure from
  any facility subject to the planning pro-
  visions of the law  information needed
 for such mandatory plan  contents  as:
 facility  equipment  and emergency  re-
  sponse capabilities,  facility emergency
  response personnel, and facility evacu-
  ation plans.

  Some of the facilities subject to Section
  302 planning requirements may not be
  subject to Sections 311-12 reporting re-
  quirements,  which are currently limited
  to manufacturers and importers in SIC
  codes 20-39.  LEPCs may use Section
  303 (d) (3) authority to gain information
  such as name(s), MSDSs,  and quantity
  and location of chemicals present at fa-
  cilities subject to Section 302.
Section 304:  Emergency Notification

If a facility produces, uses, or stores one
or more hazardous chemical,  it must im-
mediately notify the LEPC and the SERC if
there is a release of a  listed  hazardous
substance that  exceeds the  reportable
quantity for  that substance.  Substances
subject to this notification requirement  in-
clude substances on the list of extremely
hazardous substances  published  in  the
Federal Register on November 17,  1986,
and substances subject to the emergency
notification requirements of CERCLA Sec-
tion 103 (a).
                                    Page A-3

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  Information included in this initial noti-
  fication (as well as the additional infor-
  mation in  the follow-up  written notice
  described below)  can  be used by the
  LEPC  to  prepare and/or  revise  the
  emergency   plan.    This  information
  should be especially  helpful in meeting
  the requirement to list methods for de-
  termining if a release has occurred and
  identifying the area and population most
  likely to be  affected.
The initial notification of a release can be
by telephone, radio, or in person.  Emer-
gency notification requirements involving
transportation incidents may be satisfied
by dialing 911 or, in the absence of a 911
emergency number, calling  the operator.

This emergency  notification needs  to in-
clude:  the chemical name; an indication
of whether the substance is an extremely
hazardous substance;  an estimate of the
quantity released into the  environment;
the time and duration of the release; the
medium into  which the release occurred;
any known or anticipated acute or chronic
health  risks  associated  with the  emer-
gency and, where appropriate, advice re-
garding medical  attention necessary for
exposed Individuals; proper  precautions,
such  as evacuation; and the name and
telephone number of a contact person.

Section 304 also requires a follow-up writ-
ten emergency notice after  the release.
The follow-up notice or notices shall up-
date information included in the initial no-
tice and provide additional information on
actual response actions taken, any known
or anticipated data on chronic health risks
associated with the release,  and advice
regarding medical attention necessary for
exposed individuals.

The requirement  for emergency notifica-
tion comes into effect  with the establish-
ment  of the SERC and  LEPC.  If no  SERC
is established by  April 17, 1987, the Gov-
ernor becomes the SERC and notification
should be made to him/her.  If no LEPC is
established by August 17, 1987, local no-
tification must be made to the appropriate
local  emergency  response  personnel,
such as the fire department.

Sections 311-312:  Community Right-
to-Know Reporting Requirements
 As noted above, Section 303 (d) (3) gives
 LEPCs access to information from fa-
 cilities subject to Title III planning re-
 quirements.  Sections 311-12 provide
 information about the nature, quantity,
 and location of chemicals at many fa-
 cilities  not  subject  to  the  Section
 303 (d) (3)  requirement.  For this rea-
 son, LEPCs will find Sections 311-12
 information especially helpful when pre-
 paring a comprehensive plan for the en-
 tire planning district.
There are two community right-to-know
reporting requirements.  Section 311 re-
quires  a facility which  must prepare  or
have available material safety data sheets
(MSDSs) under the Occupational Safety
and Health Administration (OSHA) hazard
communications  regulations  to submit
either copies  of its MSDSs  or a list  of
MSDS chemicals to the LEPC, the SERC,
and the local fire department.  Currently,
only facilities in Standard Industrial Classi-
fication  (SIC)  Codes 20-39 (manufactur-
ers and importers) are subject to these
OSHA regulations.

The initial submission of the MSDSs or list
is  required  no  later than  October 17,
1987, or  3 months after  the  facility  is
required to prepare or have  available an
MSDS under OSHA regulations.  A revised
MSDS  must be provided  to update an
MSDS which was  originally submitted if
significant new  information regarding  a
chemical is discovered.
 EPA encourages LEPCs and fire depart-
 ments  seriously to consider  contacting
                                    Page A-4

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facilities prior to the deadline of Octo-
ber 17, 1987 to request the submission
of lists rather  than MSDS forms.   In
communities  with a large number of
facilities, handling large numbers of
chemicals, and  in communities  with
limited capabilities to store and manage
the MSDSs, the list of MSDS  chemicals
from  the facility  would be more useful
than the forms  themselves, and likely to
be more easily produced.

LEPCs also have  the option of using the
chemical names  provided to develop
additional  data  on   each   of  the
chemicals,  using a  variety   of  data
sources,  including several on-line data
bases  maintained by agencies of the
Federal government.

Specific  MSDSs could be requested on
chemicals that are of particular con-
cern.     In  general every  MSDS  will
provide   the   LEPC  and  the   fire
departments in  each community with the
following information on each of the
chemicals covered:

•  The  chemical name;

•  Its basic characteristics, for example:

   o   toxicity, corrosivity, reactivity,
   o   known  health  effects, including
       chronic  effects from exposure,
   o   basic  precautions  in  handling,
       storage,  and use,
   o   basic countermeasures  to take  in
       the event of a fire, explosion, leak,
       and
   o   basic  protective   equipment   to
       minimize exposure.

In any case, these data should be useful
for the planning to be accomplished by
the   LEPC  and  first   responders,
especially fire departments and hazmat
teams.  Both hazards analysis and the
development  of  emergency   counter-
measures should  be facilitated by the
availability of MSDS information.
If the facility owner or operator chooses to
submit a list of MSDS chemicals, the list
must  include  the chemical  name  or
common name  of each substance and
any hazardous component as provided on
the MSOS.   This list must be organized in
categories of health and physical hazards
as set forth in  OSHA regulations or as
modified by EPA.

If a list is submitted, the facility  must pro-
vide the MSDS for any chemical  on the list
upon  the request of  the LEPC.   Under
Section 311, EPA may establish threshold
quantities for hazardous chemicals below
which no facility must report.

The reporting requirement of Section 312
requires facilities to submit an emergency
and hazardous chemical inventory form to
the LEPC,  the  SERC, and the local fire
department.   The  hazardous chemicals
covered  by Section 312  are the same
chemicals for which facilities are required
to submit  MSDS  forms or  the  list for
Section 311.

Under   Sections  311-12,   EPA   may
establish    threshold    quantities    for
hazardous   chemicals  below  which  no
facility is subject to this requirement.  See
the proposed rule in the January 27, 1987
Federal Register.  The Final  Rule will be
published before October 1987.

The inventory form incorporates  a two-tier
approach.   Under Tier  I, facilities  must
submit    the    following    aggregate
information  for  each  applicable  OSHA
category of  health and physical  hazard:

  •   An  estimate  (in  ranges)  of  the
     maximum  amount  of chemicals for
     each category present at the facility
     at  any time  during  the preceding
     calendar year;

  •   An  estimate  (in  ranges)  of  the
     average daily amount of chemicals
     in each category; and

  •   The general  location  of hazardous
     chemicals in each category.
                                   Page A-5

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Tier I  information shall be submitted on or
before  March  1,   1988  and  annually
thereafter on March  1.

The public  may  also  request additional
information for specific facilities from the
SERC and LEPC.  Upon the request of the
LEPC,  the   SERC,   or  the   local   fire
department, the facility must provide the
following  Tier  II  information  for each
covered substance  to  the  organization
making the request:

  •  The chemical name or the common
     name as indicated on the MSDS;

  •  An estimate   (in  ranges)   of  the
     maximum amount of the  chemical
     present  at  any time  during  the
     preceding calendar year;

  •  A brief description of the manner of
     storage of the chemical;

  •  The location of the chemical at the
     facility; and

  •  An indication of whether the owner
     elects  to  withhold  information from
     disclosure to the public.

The information  submitted  by facilities
under   Sections  311   and   312  must
generally be made available to  the public
by  local and  State  governments  during
normal working hours.
 As in the case of the MSDS data, this
 Section 312 information may be useful
 for LEPCs interested in  extending the
 scope  of their  planning beyond the
 facilities covered by Section  302,  and
 for  reviewing  and  updating  existing
 plans.   Section 312 information about
 the quantity and location of chemicals
 can be of use to fire departments in the
 development of pre-fire plans.  Section
 312  data may be of limited use in the
 initial  planning process, given the fact
 that initial emergency plans are to be
 completed by October 17,  1988,
  but they will be useful for the subse-
 quent review and update of plans.  Fa-
  cility owners or operators, at the request
  of the fire department,  must allow the
  fire  department  to  conduct an on-site
  inspection and provide specific informa-
  tion about  the  location of hazardous
  chemicals.
Section 313:  Toxic Chemical Release
Reporting

Section 313  of  Title III requires EPA to
establish an  inventory of toxic  chemical
emissions from certain facilities.  Facilities
subject to this reporting requirement must
complete a toxic chemical release form (to
be  prepared by EPA by  June  1987)  for
specified chemicals.  The form must  be
submitted to EPA and those State officials
designated by the  Governor on or before
July 1, 1988,  and  annually thereafter  on
July 1, reflecting  releases during each
preceding calendar year.

The purpose of this reporting requirement
is to inform government officials and the
public  about  releases of toxic chemicals
into the environment. It will also assist in
research   and  the  development   of
regulations, guidelines, and standards.

The reporting  requirement  applies  to
owners and  operators  of facilities  that
have 10 or more full-time employees, that
are in Standard  Industrial Classification
(SIC)  Codes  20 through  39,  and  that
manufactured,  prdcessed, or  otherwise
used a listed toxic chemical in excess of
specified threshold quantities.   The SIC
Codes  mentioned   cover basically   all
manufacturing industries.

Facilities  using listed toxic chemicals in
quantities   over  10,000  pounds  in  a
calendar year are required to submit toxic
chemical release forms by July 1  of the
following year.  Facilities manufacturing or
processing any of  these chemicals  in
excess of 75,000  pounds in 1987 must
report  by  July   1,   1988.     Facilities
manufacturing or processing in  excess of
50,000 pounds in 1988 must report by July
                                     Page A-6

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 1,     1989.     Thereafter,     facilities
 manufacturing  or processing more than
 25,000 pounds in a year are required to
 submit the form.   EPA can  revise these
 threshold   quantities   and   the   SIC
 categories involved.

 The list of  toxic  chemicals subject to
 reporting consists initially  of  chemicals
 listed for similar reporting purposes by the
 States  of  New  Jersey  and  Maryland.
 There   are   over  300  chemicals   and
 categories on these lists.  EPA can modify
 this combined list. In adding a chemical
 to the combined Maryland and New Jersey
 lists,  EPA  must  consider  the  following
 factors:

  (1)    Is the substance known  to cause
        cancer or serious reproductive or
        neurological  disorders,   genetic
        mutations, or  other chronic health
        effects?

  (2)    Can   the    substance   cause
        significant adverse  acute health
        effects  as a result of continuous
        or frequently recurring releases?

  (3)    Can  the  substance  cause  an
        adverse effect on the environment
        because    of    its    toxicity,
        persistence,  or   tendency   to
        bioaccumulate?

Chemicals can  be deleted if there is not
sufficient evidence to  establish any of
these  factors.   State Governors or  any
other  person  may  petition  the  EPA
Administrator to add or delete a  chemical
from the list for any of the above reasons.
EPA must either publish  its reasons for
denying  the petition,  or  initiate  action to
implement the petition within 180 days.

Through early consultation with States or
EPA  Regions,    petitioners  can  avoid
duplicating   previous  petitions  and  be
assisted in  locating  sources  of  data
already  collected  on  the   problem  of
concern and data sources to support their
petitions.  EPA  will conduct  information
searches on chemicals contained  in a
petition, focusing  on  the  effects  the
petitioners believes warrant addition  or
deletion.

The toxic chemical release form includes
the  following  information  for  released
chemicals:

  •  The name,  location,  and type  of
     business;

  •  Whether     the     chemical    is
     manufactured,    processed,    or
     otherwise  used  and  the  general
     categories of use of the chemical;

  •  An  estimate (in  ranges)  of  the
     maximum  amounts  of  the  toxic
     chemical  present  at the  facility  at
     any time during the preceding year;

  •  Waste  treatment   and   disposal
     methods  and  the   efficiency   of
     methods for  each wastestream;

  •  The  quantity   of   the  chemical
     entering     each     environmental
     medium annually; and

  •  A certification by a senior official that
     the report is complete and accurate.

EPA  must  establish  and   maintain  a
national toxic chemical inventory based on
the data submitted. This information must
be  computer  accessible  on  a national
database.
 In  general  these Section 313  reports
 appear to be of limited value in emer-
 gency planning.   Over time,  however
 they may  contain information that can
 be used by local planners in developing
 a more complete understanding  of the
 total spectrum of hazards that a given
 facility  may pose  to  a  community.
 These reports will not be available to
 States until July  1, 1988.  These reports
 do not go to the LEPCs directly but they
 are likely to become  available  if the
 LEPCs request them from the States.
                                     Page A-7

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Other Title III Provisions

In addition to these four major sections of
Title III,  there  are other provisions  of
interest to local communities.
Preemption
  Section 321  stipulates  that  (with  the
  exception  of  the MSDS format  and
  content required  by  Section 311) Title
  HI does not preempt any State and local
  laws.   In effect,   Title  III  imposes
  minimum  planning and  reporting stan-
  dards where no such standards  (or less
  stringent   standards)   exist,    while
  permitting States  and  localities  to
  pursue more  stringent requirements as
  they deem appropriate.
     measures   have  been  taken
     protect the  confidentiality;
to
Trade Secrets

Section  322  of  Title  III addresses  trade
secrets  and applies to Section 303 emer-
gency  planning  and Sections 311, 312,
313   regarding   planning   information,
community    right-to-know    reporting
requirements, and toxic chemical release
reporting.  Any  person may  withhold  the
specific chemical identity of an extremely
hazardous substance or toxic  chemical for
specific reasons.   Even if the chemical
identity  is withheld, the generic class or
category  of  the  chemical  must  be
provided.  Such  information may be with-
held if the facility submits the withheld in-
formation to EPA along with an explanation
of why the information is  a trade secret.
The information  may not be withheld as a
trade secret  unless  the  facility  shows
each of the following:

  •  The   information  has   not  been
     disclosed to any other person other
     than  a member  of  the LEPC,  a
     government official, an  employee of
     such person or someone bound by a
     confidentiality  agreement, and that
  •  The information is not required to be
     disclosed to the public under  any
     other Federal or State law;

  •  The information  is likely to cause
     substantial harm  to the competitive
     position of the person; and

  •  The chemical  identity  could  not
     reasonably be discovered by anyone
     in the absence of disclosure.

Even if information can be legally  withheld
from the public,  Section 323 requires it
not   to   be   withheld   from   health
professionals who require the information
for diagnostic  purposes  or  from local
health officials who require the information
for assessment activities. In these cases,
the person receiving the information must
be  willing   to   sign  a  confidentiality
agreement with the facility.

Information claimed as trade  secret and
substantiation for that claim  must   be
submitted to EPA. People may challenge
trade  secret  claims  by petitioning EPA,
which must then review the claim  and rule
on its validity.

EPA will  publish regulations  governing
trade  secret  claims.   The regulations will
cover  the  process for  submission  of
claims,  petitions for disclosure,  and  a
review process for these petitions.


Enforcement

Section 325  identifies the  following  en-
forcement procedures:

  •  Civil penalties for facility owners or
     operators who fail  to comply with
     emergency  planning requirements;

  •  Civil,  administrative,   and  criminal
     penalties  for owners  or operators
     who fail to  comply with the emer-
     gency  notification requirements of
     Section  304;
                                     Page A-8

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  •  Civil and administrative penalties for
     owners or operators who fail to com-
     ply with the reporting requirements
     in Sections 311-313;

  •  Civil and administrative penalties for
     frivolous trade secret claims;  and

  •  Criminal penalties for the disclosure
     of trade secret information.

In addition  to the  Federal government,
State and local governments and  individ-
ual citizens may enforce the provisions of
Title  III  through the citizen suit authority
provided in Section  326.
Training

Section  305   mandates   that  Federal
emergency   training   programs   must
emphasize hazardous chemicals.  It also
authorizes   the   Federal   Emergency
Management Agency  (FEMA)  to provide
$5 million for each of fiscal years 1987,
1988, 1989, and  1990 for training  grants
to support State and local governments.
These  training  grants  are  designed  to
improve     emergency      planning,
preparedness,  mitigation,  response, and
recovery  capabilities.   Such  programs
must give special emphasis to hazardous
chemical  emergencies.    The training
grants  may not exceed 80 percent of the
cost  of  any  such  programs.   The
remaining 20  percent  must  come from
non-Federal sources.  Consult FEMA and/
or EPA Regional offices for a list of training
courses.
Review of Emergency Systems

Under  Section  305,  EPA  has initiated a
review   of   emergency   systems   for
monitoring,  detecting,  and  preventing
releases   of    extremely    hazardous
substances at representative facilities that
produce, use, or store these substances.
It also is examining public alert systems.
EPA will report interim  findings  to the
Congress no  later than May 17, 1987 and
issue  a final  report of  findings  and
recommendations  to the  Congress  by
April 17, 1988.

The  report must  include  EPA's findings
regarding each of the following:

 •   Status   of  current  technological
     capabilities to  1) monitor, detect,
     and prevent significant releases of
     extremely hazardous substances; 2)
     determine   the  magnitude    and
     direction of  the hazard  posed  by
     each  release;  3)  identify  specific
     substances;  4)  provide data on the
     specific   chemical   composition  of
     such  releases;  and 5)  determine
     relative    concentrations   of   the
     constituent substances;

 •   Status  of public emergency  alert
     devices   or  systems for effective
     public warning of accidental releases
     of extremely  hazardous substances
     into any media; and

 •   The   technical  and   economic
     feasibility      of      establishing,
     maintaining,   and   operating   alert
     systems for detecting releases.

The  report  must  also   include  EPA's
recommendations for the following:

 •   Initiatives to support development of
     new or  improved   technologies or
     systems that would  assist the timely
     monitoring,      detection,      and
     prevention of releases of extremely
     hazardous substances; and

 •   Improving devices  or  systems for
     effectively alerting the  public  in the
     event of an accidental release.
                                    Page A-9

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                                  EXHIBIT 5

                           KEY TITLE III DATES
The following is a list of some key dates relative to the implementation of the " Emergency
Planning and Community Right-to-Know Act of 1986."
November 17, 1986



November 17, 1986


January 27,  1987



March 17, 1987



April 17. 1987

May 17, 1987


June 1,  1987


July 17. 1987
August 17, 1987
(or 30 days after
designation of
districts, which-
ever is sooner)

September 17, 1987
(or 30 days after
local committee is
formed, whichever
is earlier)

October 17, 1987
March 1, 1988
April 17,  1988
July 1, 1988
(and annually
hereafter)

October 17,  1988
•  EPA publishes interim final List of Extremely
   Hazardous Substances and their Threshold Planning
   Quantities in Federal Register  (§ 302 (a) (2-3))

•  EPA initiates comprehensive review of emergency
   systems (§ 305 (b))

•  EPA publishes proposed formats for emergency
   inventory forms and reporting requirements in Federal
   Register (§ 311-12)

•  National Response Team publishes guidance for
   preparation and implementation of emergency plans
   (§ 303 (f))

•  State Governors appoint SERCs (§ 301 (a))

•  Facilities subject to Section 302 planning requirements
   notify SERC  (§ 302 (c))

•  EPA publishes toxic chemicals  release (i.e., emissions
   inventory) form (§ 302(c))

•  SERC designates emergency planning districts
   (§ 301 (b))

•  SERC appoints members of LEPCs  (§ 301 (c))
   Facility notifies LEPC of selection of a facility
   representative to serve as facility emergency
   coordinator (§ 303(d)(1))
   MSDSs or list of MSDS chemicals submitted to SERC,
   LEPC, and local fire department (§ 311(d))

   Facilities submit their initial emergency inventory
   forms to SERC, LEPC, and local fire department
   (§  312(a)(2))

   Final report on emergency systems study due to
   Congress (§ 305(b))

   Facilities to submit initial toxic chemical release forms
   to EPA and designated State officials (§ 313(a))
   LEPCs complete preparation of an emergency plan
   (§ 303(a))
                                  Page A-10

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                                               EXHIBIT 6
                        TITLE III - MAJOR INFORMATION FLOW/REQUIREMENTS
Guidance/
Assistance
  (§303)
  NRT
  RRT
EPA
   State
Commission
  (SERC)
                                Designated
                                State Official
  Emergency
Response Plan
  Local
Committee
  (LEPC)
   Fire
Department
                                                       Emergency
                                                       Notification
                                                         (§304)
                                               Emergency
                                                Planning
                                              (§301-§303)
              Toxic Chemical
               Release Form
                  (§313)
                                   FACILITIES
                                                                     Emergency
                                                                      Inventory-
                                                                       (§312)
                                                   MSDS or
                                                      List
                                                    (§311)

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                                                        EXHIBIT 7
                            INFORMATION FROM FACILITIES PROVIDED BY TITLE III
                                   IN SUPPORT OF LEPC PLAN DEVELOPMENT
   Information Generated by
       Title III Compliance
       Authority
    How LEPC Can Use
      the Information
Facilities subject to Title III planning requirements
(including those designated by the Governor or SERC)


Additional facilities near subject facilities (such as hospitals,
natural gas facilities, etc.)
Transportation routes
Major chemical hazards (chemical name, properties,
location, and quantity)
Facility and community response methods, procedures,
and personnel

Facility and community emergency coordinators
Release detection and notification procedures



Methods for determining release occurrence and
population affected

Facility equipment and emergency facilities; persons
responsible for such equipment and facilities

Evacuation plans


Training programs


Exercise methods and schedules
Section 302;
Notice from Governor/SERC


Sections 302 (b) (2); 303 (c)(1)
Sections 303 (c)(1); 303 (d) (3)
Section 303 (d) (3) for extremely
hazardous substances used,
produced, stored

Section 311 MSDSs for chemicals
manufactured or imported

Section 312 inventories for
chemicals manufactured or imported
Sections 303 (c) (2); 303 (d) (3)


Sections 303 (c) (3); 303(d)(1)


Sections 303 (c) (4); 303 (d) (3)



Sections 303 (c) (5); 303 (d) (3)


Sections 303 (c) (6); 303 (d) (3)


Sections 303 (c) (7); 303 (d) (3)


Sections 303 (c) (8); 303 (d) (3)


Sections 303 (c) (9); 303 (d) (3)
Hazards analysis — Hazards
identification (see p. 64)


Hazards analysis — Vulnerability
analysis (see p. 64)
Hazards analysis — Hazards
identification (see p. 64)

Hazards analysis — Hazards
identification (see p. 64)
Response functions (see pp. 49ff)
Assistance in preparing and
implementing the plan (see p. 11)

Initial notification (see p. 50)
Warning systems (see p. 53)


Hazards analysis — Vulnerability
analysis and risk analysis (see p. 64)

Resource management (see p. 54)
Evacuation planning (see p. 57)


Resource management (see p. 54)


Testing and updating  (see p. 63)

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                                                          EXHIBIT 8
                                TITLE III CHEMICAL  LISTS AND THEIR PURPOSES
               List
      Required in Section
                                              Purpose
Extremely Hazardous Substances
(Federal Register 11/17/86 — initially
402 chemicals listed in CEPP Interim
Guidance)
Section 302:  Emergency Planning
                                         Section 304:  Emergency Notification
                              Facilities with more than established planning
                              quantities of these substances must notify the
                              SERC.
                              Initial focus for preparation of emergency plans
                              by LEPCs

                              Certain releases of these chemicals trigger
                              Section 304 notification to SERC and LEPC.
Substance requiring notification under
Section 103 (a) of CERCLA  (717
chemicals)
Section 304:  Emergency Notification
                              Certain releases of these chemicals trigger
                              Section 304 notification to SERC and LEPC as well
                              as CERCLA Section 103 (a) requirement to
                              notify National Response Center.
Hazardous Chemicals considered
physical or health hazards under OSHA's
Hazard Communication Standard (This
is a performance standard, there is no
specific list of chemicals.)
Section 304:  Emergency Notification
Section 311:  Material Safety Data Sheets
                                         Section 312:  Emergency and Hazardous
                                                      Chemical Inventory
                            • Identifies facilities subject to emergency notification
                              requirements

                            • MSDS or list of MSDS chemicals provided by
                              facilities to SERC, LEPC, and local fire
                              department

                            • Covered facilities provide site-specific information
                              on the quantity and location of chemicals to SERC,
                              LEPC, and local fire departments to inform the
                              community and assist in plan preparation.
Toxic Chemicals identified as chemicals
of concern by States of New Jersey and
Maryland (329 chemicals/chemical
categories)
Section 313:
Toxic Chemical Release
Reporting
• These chemicals are reported on an emissions
  inventory to inform government officials and the
  public about releases of toxic chemicals in the
  environment.

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                              APPENDIX B
    LIST OF ACRONYMS AND RECOGNIZED ABBREVIATIONS

AAR/BOE        Association of American Railroads/Bureau of Explosives
AlChE           American Institute of Chemical Engineers
ASCS           Agricultural Stabilization and Conservation Service
ASME           American Society of Mechanical Engineers
ASSE           American Society of Safety Engineers
ATSDR          Agency for Toxic Substances and Disease Registry (HHS)
CAER           Community Awareness and Emergency Response (CMA)
CDC            Centers for Disease Control (HHS)
CEPP           Chemical Emergency Preparedness Program
CERCLA         Comprehensive Environmental Response, Compensation,  and Liabil-
                ity Act of 1980 (PL 96-510)
CFR            Code of Federal Regulations
CHEMNET       A mutual  aid network of chemical shippers and contractors.
CHEMTREC      Chemical Transportation Emergency Center
CHLOREP        A mutual  aid group comprised of shippers and carriers of chlorine.
CHRIS/HACS     Chemical Hazards Response Information System/Hazard Assessment
                Computer System
CMA            Chemical Manufacturers Association
CPG 1-3         Federal Assistance Handbook:  Emergency Management,  Direction
                and Control Programs
CPG 1-8         Guide for Development of State and Local Emergency Operations
                Plans
CPG 1-8A       Guide for the Review of State and Local Emergency Operations
                Plans
CWA            Clean Water Act
DOC            U.S. Department of Commerce
DOD            U.S. Department of Defense
DOE            U.S. Department of Energy
DOI             U.S. Department of the Interior
DOJ            U.S. Department of Justice
DOL            U.S. Department of Labor
DOS            U.S. Department of State
DOT            U.S. Department of Transportation
                                 Page B-l

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                         APPENDIX B (Continued)
    LIST OF ACRONYMS AND RECOGNIZED ABBREVIATIONS
EENET
EMA
EMI
EOC
EOF
EPA
ERD
FEMA
FEMA-REP-5

FWPCA
HAZMAT
HAZOP
HHS
ICS
IEMS
LEPC
MSDS
NACA
NCP
NCRIC
NETC
NFA
NFPA
NIOSH
NOAA
NRC
NRT
NUREG 0654/
FEMA-REP-1

OHMTADS
Emergency Education Network (FEMA)
Emergency Management Agency
Emergency Management Institute
Emergency Operating Center
Emergency Operations Plan
U.S. Environmental Protection Agency
Emergency Response Division (EPA)
Federal Emergency Management Agency
Guidance for Developing State and Local Radiological Emergency
Response Plans and Preparedness for Transportation Accidents
Federal Water  Pollution Control Act
Hazardous  Materials
Hazard and Operability Study
U.S. Department of Health and Human Services
Incident Command System
Integrated Emergency Management System
Local Emergency Planning Committee
Material  Safety Data Sheet
National Agricultural Chemicals Association
National Contingency Plan
National Chemical Response and Information Center  (CMA)
National Emergency Training Center
National Fire Academy
National Fire Protection Association
National Institute of Occupational Safety and Health
National Oceanic and Atmospheric Administration
U.S. Nuclear Regulatory Commission; National Response Center
National Response Team
Criteria for Preparation and Evaluation of Radiological Emergency
Response Plans and Preparedness in Support of Nuclear Power
Plants
Oil and Hazardous Materials Technical Assistance Data  System
                                 Page B-2

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                        APPENDIX B (Continued)
   LIST OF ACRONYMS AND  RECOGNIZED ABBREVIATIONS

OSC            On-Scene Coordinator
OSHA          Occupational Safety and  Health Administration (DOL)
PSTN          Pesticide Safety Team Network
RCRA          Resource Conservation and Recovery Act
RQs            Reportable Quantities
RRT            Regional Response Team
RSPA          Research and Special Programs Administration (DOT)
SARA          Superfund Amendments and Reauthorization Act of 1986
               (PL 99-499)
SCBA          Self-Contained Breathing Apparatus
SERC          State Emergency Response Commission
SPCC          Spill Prevention Control and Countermeasures
TSD            Treatment, Storage, and Disposal Facilities
USCG          U.S. Coast Guard (DOT)
USDA          U.S. Department of Agriculture
USGS          U.S. Geological Survey
USNRC         U.S. Nuclear Regulatory Commission
                                Page B-3

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                                APPENDIX C
                                GLOSSARY
CAER
CEPP


CERCLA




CHEMNET
CHEMTREC
CHLOREP
Community Awareness and Emergency Response program devel-
oped by the Chemical Manufacturers Association.  Guidance for
chemical plant managers to assist them in taking the initiative  in
cooperating with local communities to develop integrated  (com-
munity/industry) hazardous materials response plans.

Chemical Emergency Preparedness Program developed by EPA
to address accidental releases of acutely toxic chemicals.

Comprehensive Environmental Response, Compensation, and Li-
ability Act regarding hazardous substance releases into the envi-
ronment and the cleanup of inactive hazardous waste disposal
sites.

A mutual aid network of chemical shippers and contractors.
CHEMNET has  more than fifty participating companies with emer-
gency teams, twenty-three subscribers (who receive services  in
an incident from a participant and then reimburse response and
cleanup costs), and several emergency response contractors.
CHEMNET is activated when a member shipper cannot respond
promptly to an incident involving that company's product(s) and
requiring the presence of a chemical expert.  If a member com-
pany cannot go the scene of the incident, the shipper will author-
ize a CHEMNET-contracted emergency response company to go.
Communications for the network are provided by CHEMTREC,
with the shipper receiving notification and details about  the inci-
dent from the CHEMTREC communicator.

Chemical Transportation Emergency Center operated by the
Chemical Manufacturers Association. Provides information and/or
assistance to emergency responders.  CHEMTREC contacts the
shipper or producer of the material for more detailed information,
including on-scene assistance when feasible.  Can be reached
24 hours a day by calling 800-424-9300.  (Also see "HIT.")

Chlorine Emergency Plan operated by the  Chlorine Institute. A
24-hour mutual aid program.  Response is activated by a
CHEMTREC call to the designated CHLOREP contact, who notifies
the appropriate team leader, based  upon CHLOREP's geographi-
cal sector assignments for teams.  The team leader in turn calls
the emergency caller at the incident scene and determines what
advice and assistance are  needed.   The team leader then de-
cides whether or not to dispatch his team to the  scene.
                                   Page C- 1

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                          APPENDIX C (Continued)
                                GLOSSARY
CHRIS/HACS     — Chemical Hazards Response Information System/Hazard Assess-
                    ment Computer System developed by the U.S. Coast Guard.
                    HAGS is a computerized model of the four CHRIS manuals that
                    contain chemical-specific data.  Federal OSCs use HACS to find
                    answers to specific questions during a chemical spill/response.
                    State and local officials and industry representatives may ask an
                    OSC to request a HACS run for contingency planning purposes.

CPG 1-3         — Federal Assistance Handbook:  Emergency Management, Direc-
                    tion and Control Programs, prepared by FEMA.  Provides States
                    with guidance  on administrative and programmatic requirements
                    associated with FEMA funds.

CPG 1-5         — Objectives for  Local Emergency Management, prepared by
                    FEMA.  Describes and explains functional objectives that repre-
                    sent a comprehensive and integrated emergency management
                    program.  Includes recommended activities for each objective.

CPG 1-8         — Guide for Development of State and  Local Emergency Operations
                    Plans, prepared by FEMA (see EOP below).

CPG 1-8A        — Guide for the Review of State and Local Emergency Operations
                    Plans, prepared by FEMA.  Provides FEMA staff with a standard
                    instrument for  assessing EOPs that are developed to satisfy  the
                    eligibility requirement to receive Emergency Management Assis-
                    tance funding.

CPG 1-35        — Hazard  Identification,  Capability Assessment, and Multi-Year De-
                    velopment Plan for Local Governments, prepared by FEMA.  As a
                    planning tool, it can guide local jurisdictions through a logical se-
                    quence for identifying hazards, assessing capabilities, setting pri-
                    orities, and scheduling activities to improve capability over time.

EBS             — Emergency Broadcasting System to be used to inform the public
                  .  about the nature of a hazardous materials incident and what
                    safety steps they should take.

EMI              — The Emergency Management Institute is a component of FEMA's
                    National Emergency Training Center located in Emmitsburg, Mary-
                    land.  It conducts  resident and nonresident training  activities for
                    Federal, State, and local government officials, managers in the
                    private economic sector, and members of professional and vol-
                    unteer organizations on subjects that range from civil nuclear
                    preparedness systems to domestic emergencies caused by  natu-
                    ral  and technological  hazards.  Nonresident training activities are
                    also conducted by State Emergency Management Training Offices
                    under cooperative agreements that offer financial and technical
                    assistance to establish annual training programs that fulfill emer-
                    gency management training requirements in communities
                    throughout the nation.
                                    Page C-2

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                          APPENDIX C (Continued)
                                 GLOSSARY
ERT
EOP
FAULT-TREE
ANALYSIS
FEMA-REP-5
HAZARDOUS
MATERIALS
Environmental Response Team, a group of highly specialized ex-
perts available through EPA 24 hours a day.

Emergency Operations Plan developed in accord with the guid-
ance in CPG  1-8.  EOPs are multi-hazard, functional plans that
treat emergency management activities generically. EOPs pro-
vide for as much generally applicable capability as possible with-'
out reference to any particular hazard; then they address the
unique aspects of individual disasters in hazard-specific appendi-
ces.

A means of analyzing hazards.  Hazardous events are first iden-
tified by other techniques such as HAZOP. Then all combinations
of individual failures that can lead to that hazardous event are
shown in the  logical format of the fault tree.  By estimating the
individual failure probabilities, and then using the appropriate ar-
ithmetical expressions, the top-event frequency can be calcu-
lated.

Guidance for  Developing State and Local Radiological Emergency
Response Plans and Preparedness for Transportation Accidents,
prepared by FEMA.  Provides a basis for State and local govern-
ments to develop emergency plans and improve emergency pre-
paredness for transportation accidents involving radioactive mate-
rials.

Refers generally to hazardous substances, petroleum,  natural
gas, synthetic gas, acutely toxic chemicals, and  other toxic
chemicals.
HAZOP
Hazard and operability study, a systematic technique for identify-
ing hazards or operability problems throughout an entire facility.
One examines each segment of a process and lists all possible
deviations for normal operating conditions and how they might
occur. The consequences on the process are assessed, and
the means available to detect and correct the deviations are ex-
amined.
HIT
Hazard Information Transmission program provides a digital
transmission of the CHEMTREC emergency chemical report to
first responders at the scene of a hazardous materials incident.
The report advises the responder on the hazards of the materi-
als, the level of protective clothing required, mitigating action to
take in the event of a spill, leak or fire, and first aid for victims.
HIT is a free public service provided  by the Chemical Manufactur-
ers Association.  Reports are sent in emergency situations only
to organizations that have  pre-registered with HIT.   Brochures
and registration forms may be obtained by writing:  Manager,
CHEMTREC/CHEMNET, 2501 M  Street,  N.W., Washington, DC,
20037.
                                    Page C-3

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                          APPENDIX C (Continued)
                                 GLOSSARY
ICS              — Incident Command System, the combination of facilities,
                    equipment,  personnel, procedures, and communications operat-
                    ing within a  common organizational structure with responsibility
                    for management of assigned resources to effectively accomplish
                    stated objectives at the scene  of an incident.

IEMS            — Integrated Emergency Management System, developed by FEMA
                    in recognition of the economies realized in planning for all haz-
                    ards on a generic functional basis as opposed to developing in-
                    dependent structures and resources to deal with each type of
                    hazard.

NCP             — National Oil and Hazardous Substances Pollution Contingency Plan
                    (40 CFR Part 300), prepared by EPA to put into effect the re-
                    sponse powers and responsibilities created by CERCLA and the
                    authorities established by Section 311 of the Clean Water Act.

NFA             — The National Fire Academy is a component of  FEMA's National
                    Emergency Training Center located in Emmitsburg, Maryland.  It
                    provides fire prevention and control training for the fire service
                    and allied services.  Courses on campus are offered in technical,
                    management, and prevention subject areas.  A growing off-cam-
                    pus course delivery system is operated in conjunction with State
                    fire training program offices.

NHMIE           — National Hazardous Materials  Information Exchange,  provides
                    information on hazmat training  courses,  planning techniques,
                    events and conferences, and emergency response experiences
                    and lessons learned.  Call toll-free  1-800-752-6367 (in Illinois,
                    1-800-367-9592).   Planners with personal computer capabilities
                    can access NHMIE  by  dialing FTS 972-3275 or (312) 972-3275.

NRC             — National Response Center, a  communications center for activities
                    related  to response actions, is  located at Coast Guard headquar-
                    ters in Washington,  DC. The NRC receives and relays notices of
                    discharges or releases to the appropriate OSC, disseminates
                    OSC and RRT reports to the NRT when appropriate,  and provides
                    facilities for the NRT to use in coordinating a national response
                    action when required.  The toll-free number (800-424-8802, or
                    202-426-2675 or 202-267-2675 in the Washington,  DC area) can
                    be reached 24 hours a day for reporting actual or potential pollu-
                    tion incidents.

NRT             — National Response Team,  consisting of representatives of 14
                    government  agencies  (DOD,  DOI. DOT/RSPA, DOT/USCG, EPA,
                    DOC, FEMA, DOS,  USDA, DOJ, HHS, DDL, Nuclear  Regulatory
                    Commission, and DOE), is the  principal organization for imple-
                    menting the NCP.  When the NRT is not activated for a response
                    action,  it serves as a standing  committee to develop and main-
                    tain preparedness,  to evaluate  methods of responding to dis-
                    charges or releases, to recommend needed changes in the re-
                                    Page C-4

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                          APPENDIX C (Continued)
                                 GLOSSARY
                    sponse organization, and to recommend revisions to the NCP.
                    The NRT may consider and make recommendations to appropri-
                    ate agencies on the training, equipping, and protection of  re-
                    sponse teams;  and necessary  research, development, demon-
                    stration, and evaluation to improve response capabilities.

NSF             — National Strike Force,  made up of three Strike Teams.
                    The USCG counterpart to the EPA ERTs.

NUREG 0654/    — Criteria  for Preparation  and Evaluation of Radiological Emergency
FEMA-REP-1        Response Plans and Preparedness in Support of Nuclear Power
                    Plants,  prepared by NRG and FEMA.  Provides a basis for State
                    and local government  and nuclear facility operators to develop
                    radiological emergency plans and improve emergency prepared-
                    ness.  The criteria also will be  used by Federal agency reviewers
                    in determining the adequacy of State, local, and nuclear facility
                    emergency plans and  preparedness.
OHMTADS
OSC
PSTN
Oil and Hazardous Materials Technical Assistance Data System, a
computerized data base containing chemical,  biological, and toxi-
cological information about hazardous substances.  OSCs use
OHMTADS to identify unknown chemicals and  to learn how to
best handle known chemicals.

On-Scene Coordinator, the Federal official predesignated  by EPA
or USCG to coordinate and direct Federal responses and remov-
als under the NCP;  or the DOD official designated to coordinate
and direct the removal actions from releases  of hazardous sub-
stances,  pollutants, or contaminants from DOD vessels and facili-
ties. When the NRC receives notification of a pollution incident,
the NRC Duty Officer notifies the appropriate OSC, depending on
the location of an incident.  Based on this initial report and any
other information that can be obtained, the OSC makes a prelimi-
nary assessment of the need for a Federal response.  If an on-
scene response is required, the OSC will go to the scene and
monitor the response of the responsible party or State or local
government.  If the responsible party is unknown or not taking
appropriate action,  and the response is beyond the capability of
State and local governments, the OSC may initiate  Federal ac-
tions, using funding from the FWPCA Pollution Fund for oil dis-
charges and the CERCLA Trust Fund (Superfund) for hazardous
substance releases.

Pesticide Safety Team Network operated by the National Agricul-
tural Chemicals Association to minimize environmental damage
and injury arising from accidental pesticide spills or leaks.  PSTN
area coordinators in ten regions nationwide are available 24
hours a day to receive pesticide incident notifications from
CHEMTREC.
                                    Page C-5

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                          APPENDIX C (Continued)
                                 GLOSSARY
RCRA
RRT
SARA



Superfund


Title III
Resource Conservation and Recovery Act (of 1976) established a
framework for the proper management and disposal of all
wastes. RCRA directed EPA to identify hazardous wastes,  both
generically and by listing specific wastes and industrial process
waste streams.  Generators and transporters are required to use
good management practices and to track the movement of
wastes with a manifest system.  Owners and operators of treat-
ment, storage, and disposal facilities also must comply with stan-
dards,  which are generally implemented through permits issued
by EPA or authorized States.

Regional Response Teams composed of representatives of Fed-
eral agencies and a representative from each State in the Fed-
eral region.  During a  response to a  major hazardous materials
incident involving transportation or a fixed facility, the OSC may
request that the RRT be convened to provide advice or recom-
mendations in specific issues requiring  resolution.  Under the
NCP, RRTs may be convened by the chairman when a hazardous
materials discharge or release exceeds the response capability
available to the OSC in the place where it occurs; crosses re-
gional boundaries; or may pose  a substantial threat to the  public
health, welfare, or environment,  or to regionally significant
amounts of property.  Regional contingency  plans  specify de-
tailed criteria for  activation of RRTs.  RRTs may review plans de-
veloped in compliance with Title  III, if the local emergency plan-
ning committee so requests.

The " Superfund Amendments and Reauthorization Act of 1986."
Title III  of SARA includes detailed provisions for community plan-
ning.

The trust fund established under CERCLA to provide money the
OSC can use during a cleanup.

The "Emergency Planning and Community Right-to-Know Act of
1986."  Specifies requirements for organizing the  planning proc-
ess at  the State and local levels for specified extremely hazard-
ous substances;  minimum plan content; requirements for fixed
facility  owners and operators to inform  officials about extremely
hazardous substances present at the facilities; and mechanisms
for making information about extremely hazardous substances
available to citizens.  (See Appendix A.)
                                    Page C-6

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                                 APPENDIX D
               CRITERIA FOR ASSESSING  STATE AND
                         LOCAL PREPAREDNESS
C.1  INTRODUCTION

The criteria  in this appendix,  an adaptation of criteria developed by the Preparedness
Committee of the NRT in August 1985, represent a basis for assessing a State or local
hazardous materials emergency response preparedness program.  These criteria reflect
the basic elements judged to be important for a successful emergency preparedness
program.

The criteria are separated into six categories, all of which are closely interrelated. These
categories are hazards analysis, authority, organizational structure, communications, re-
sources, and emergency planning.

These criteria may be used for assessing the emergency plan as well as the emergency
preparedness program in general.  It must be recognized, however, that few State or
local governments will have the need and/or capability to address all these Issues and
meet all these criteria to the  fullest extent. Resource limitations and the results of the
hazards analysis will strongly influence the necessary degree of planning and  prepared-
ness. Those governmental units that do not have adequate resources are encouraged to
seek assistance and take advantage of all resources that are available.

Other criteria exist that could  be used for assessing  a community's preparedness and
emergency planning. These include FEMA's CPG 1-35 (Hazard Identification,  Capability
Assessment and Multi-Year Development Plan for Local Governments) and CPG 1-8A.
Additionally,  States may have  issued criteria for assessing capability.

C.2  THE CRITERIA

C.2.1 Hazards Analysis

"Hazards Analysis" includes the procedures for determining the susceptibility  or vulner-
ability of a geographical  area to a hazardous materials release, for identifying potential
sources of a hazardous materials release from fixed facilities that manufacture, process,
or otherwise use, store, or dispose of materials that are generally considered hazardous
in an unprotected environment. This also  includes an analysis of the potential or probable
hazard of transporting hazardous materials through a  particular area.

A hazards analysis is generally considered to consist of identification of potential hazards,
determination of the vulnerability of an area as a  result of the existing hazards, and an
assessment  of the risk of a hazardous materials  release or spill.

The following criteria may assist in assessing a hazards analysis:

    D   Has a hazards analysis  been completed for the area?  If one exists, when was it
        last updated?

    D   Does the hazards analysis include the location, quantity, and types of hazardous
        materials that are  manufactured, processed, used, disposed, or stored within
        the appropriate area?
                                    Page D-l

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     D   Was it done in accordance with  community right-to-know laws and prefire
         plans?

     D   Does it include the routes by which the hazardous materials are transported?

     D   Have areas of public health concern been identified?

     D   Have sensitive environmental areas been identified?

     a   Have historical  data on spill incidents been collected and evaluated?

     Q   Have the levels of vulnerability and probable locations of hazardous  materials
         incidents been  identified?

     D   Are environmentally sensitive areas and population centers  considered in ana-
         lyzing the hazards of the transportation routes and fixed facilities?

C.2.2  Authority

"Authority"  refers to those statutory authorities or other legal authorities vested in any
personnel, organizations, agencies,  or other entities in responding to or being  prepared
for responding to hazardous materials emergencies resulting from releases or  spills.

The following criteria may be used to assess the existing legal authorities for  response
actions:

     D   Do clear legal authorities exist to establish a comprehensive hazardous  materials
         response mechanism  (Federal, State, county, and local laws,  ordinances,  and
         policies)?

     D   Do these authorities delegate command and control responsibilities between the
         different organizations within the same level of government (horizontal), and/or
         provide coordination procedures to be followed?

     D   Do they specify what agency (ies) has (have) overall  responsibility for directing
         or coordinating  a  hazardous materials response?

     D   Do they specify what agency (ies) has (have) responsibility for providing assis-
         tance or support  for hazardous materials response  and what  comprises  that
         assistance or support?

     D   Have the agency(ies) with authority to order  evacuation of the community been
         identified?

     D   Have any limitations in the  legal authorities been identified?

C.2.3  Organizational Structure

"Organization" refers to the organizational structure in place for responding to emergen-
cies. This structure will, of course, vary considerably from State to State and from locality
to locality.

There are two basic types  of organizations involved in emergency response operations.
The first is involved in the planning  and policy decision process similar to the  NRT and
RRT.  The second is the operational response group that functions within the precepts set
forth in the  State or local  plan.  Realizing that situations vary from State to State and
                                     Page D-2

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locality to locality and that emergency planning for the State and local level may involve
the preparation of multiple situation plans or development of a single comprehensive plan,
the criteria should be broadly based  and designed to detect a potential flaw that would
then precipitate a more detailed review.
    D   Are the following organizations included in the overall hazardous materials emer-
         gency preparedness activities?
         •   Health organizations (including mental health organizations)
         •   Public safety
             o  fire
             o  police
             o  health and safety (including occupational safety and  health)
             o  other responders
         •   Transportation
         •   Emergency management/response planning
         •   Environmental organizations
         •   Natural resources agencies (including trustee agencies)
         •   Environmental agencies with responsibilities for:
             o   fire
             o   health
             o   water quality
             o  air quality
             o  consumer  safety
         •   Education system  (in general)
             o  public education
             o  public information
         •   Private sector interface
             o  trade organizations
             o  industry officials
         •   Labor  organizations
    D   Have  each organization's authorities, responsibilities, and  capabilities  been de-
         termined for pre-response (planning and prevention), response (implementing
         the plan during an incident), and post-response (cleanup and restoration) activi-
         ties?

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     D   Has one organization  been given the command and control  responsibility for
        'these three phases of emergency response?

     D   Has a "chain of command" been established for response control through all
         levels of operation?

     D   Are the  roles, relationships, and coordination procedures between government
         and non-government (private entities) delineated?  Are they understood by all
         affected parties?  How are they instituted (written, verbal)?

     D   Are clear interrelationships, and coordination procedures between government
         and non-government (private entities) delineated?  Are they understood by all
         affected parties?  How are they instituted (written, verbal)?

     D   Are the  agencies or departments that provide technical guidance during a re-
         sponse the same agencies or departments that provide technical guidance in
         non-emergency situations?  In other words, does the organizational structure
         vary with the type of situation to be  addressed?

     D   Does the organizational  structure  provide a mechanism to meet  regularly for
         planning and coordination?

     D   Does the organizational structure provide a mechanism to regularly exercise the
         response organization?

     D   Has a simulation exercise been conducted within the last year to test the organ-
         izational structure?

     D   Does the organizational structure provide a  mechanism  to  review the activities
         conducted during a response or exercise to correct shortfalls?

     D   Have any limitations within  the organizational structure been identified?

     D   Is the organizational structure compatible with the Federal response organization
         in the NCR?

     D   Have trained and equipped incident  commanders been  identified?

     D   Has the  authority for site decisions been vested in the incident commanders?

     Q   Have the funding sources for a response been identified?

     D   How quickly can  the response system be activated?

C.2.4  Communication

"Communication" means any form or forms of exchanging information or ideas for emer-
gency response with other entities, either internal or external to the existing organizational
structure.

     Coordination:
     D   Have procedures been established for coordination of information during a re-
         sponse?

     D   Has one organization been  designated to coordinate communications activities?
                                     Page D-4

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D   Have  radio frequencies been established to facilitate coordination between dif-
     ferent organizations?

 Information Exchange:

D   Does a formal system exist for information sharing among agencies, organiza-
     tions,  and the private sector?

D   Has a  system been established to ensure that "lessons learned" are passed to
     the applicable organizations?

 Information Dissemination:

D   Has a system been identified to carry out public information/community relations
     activities?

D   Has one organization or individual been designated to coordinate with  or speak
     to the media  concerning the release?

D   Is there a communication link with an Emergency Broadcast System  (EBS) point
     of entry (CPCS-1)  station?

D   Does a communications system/method exist to disseminate information to re-
     sponders, affected public,  etc.?

D   Is this system available 24-hours per day?

D   Have alternate systems/methods of communications been identified for use if
     the primary method fails?

D   Does a mechanism exist to keep telephone rosters up-to-date?

D   Are communications networks tested on a regular basis?

 Information Sources and Database Sharing:

D   Is a system available to provide responders with rapid information on the haz-
     ards of chemicals involved in an incident?

D   Is this  information available on a 24-hour basis?  Is it  available in computer soft-
     ware?

D   Is a system in place to update the  available information sources?

 Notification Procedures:
Q   Have specific procedures for notification of a hazardous materials incident been
     developed?

D   Are multiple notifications  required  by overlapping requirements  (e.g., State,
     county, local  each  have specific notification requirements)?

D   Does the initial notification system have a standardized list of information that is
     collected for each incident?

D   Does a network exist for notifying and activating necessary response personnel?
                                 Page D-5

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    D   Does a network exist for notifying or warning the public of potential hazards re-
         sulting from a release?  Does this network have provisions for informing  the
         public what hazards to expect, what precautions to take, whether evacuation is
         required, etc.?

    D   Has a central location or phone number been established for initial notification of
         an incident?

    D   Is the central location or phone number accessible on a 24-hour basis?

    D   Does the central location phone system have the ability to expand to a multiple
         line system during an emergency?

     Clearinghouse Functions:

    D   Has a central clearinghouse for hazardous  materials information been  estab-
         lished with access by the public  and  private sector?

C.2.5  Resources

"Resource" means the personnel, training, equipment, facilities, and other sources avail-
able for use in responding to hazardous materials emergencies.  To the extent that the
hazards analysis has identified the appropriate level of preparedness for the area, these
criteria may be used  in evaluating available resources of the jurisdiction undergoing re-
view.

     Personnel:

    D   Have the numbers of trained personnel available for  hazardous materials been
         determined?

    D   Has the location of trained personnel available for hazardous  materials been
         determined?  Are these  personnel located  in areas identified  in the hazards
         analysis as:

         •   heavily populated;

         •   high hazard areas - i.e., numbers of chemical (or other hazardous materi-
             als) production facilities in well-defined  areas;

         •   hazardous materials storage, disposal, and/or treatment facilities; and

         •   transit routes?

    D   Are sufficient personnel available to maintain a given level of response capability
         identified as  being required for the area?

    D   Has the availability of special technical expertise  (chemists, industrial hygienists,
         toxicologists, occupational health physicians,  etc.)  necessary for response been
         identified?

    D   Have limitations on the  use of above  personnel  resources been identified?

    D   Do mutual aid agreements exist to facilitate interagency support between organi-
         zations?
                                     Page D-6

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 Training:

D   Have the training needs for the State/local area been identified?

D   Are centralized response training facilities available?

D   Are specialized courses available covering topics such as:

     •   organizational structures for response actions (i.e., authorities and coordi-
         nation) ;

     •   response  actions;

     •   equipment selection, use, and  maintenance; and

     •   safety and first aid?

D   Does the organizational structure provide training and cross training for or be-
     tween organizations in the response mechanism?

D   Does an organized training  program for all involved response personnel exist?
     Has one agency been designated to coordinate this training?

D   Have training standards or criteria been established for a given level of response
     capability?  Is any certification  provided upon completion of the training?

D   Has the level of training  available been matched to the responsibilities  or capa-
     bilities of the personnel  being trained?

D   Does a system exist for evaluating the effectiveness  of training?

D   Does the  training program provide for  "refresher courses"  or some other
     method to ensure that personnel remain up-to-date in their level of expertise?

a   Have resources and organizations available to provide training been identified?

D   Have standardized curricula been established to  facilitate consistent Statewide
     training?

Equipment:
D   Have response equipment requirements been identified for a given level of re-
     sponse capability?

D   Are the following types of equipment available?

     •   personal protective  equipment

     •   first aid and other medical emergency equipment

     •   emergency vehicles available for  hazardous  materials response

     •   sampling equipment (air, water,  soil, etc.)  and  other monitoring devices
         (e.g., explosivity meters, oxygen  meters)

     •   analytical equipment or facilities available for sample analyses
                                 Page D-7

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     •   fire-fighting equipment/other equipment and material (bulldozers,  boats,
         helicopters, vacuum trucks, tank trucks, chemical retardants, foam)

D   Are sufficient quantities of each type of equipment available on a sustained ba-
     sis?

D   Is all available equipment capable of operating in the local  environmental condi-
     tions?

D   Are up-to-date equipment lists maintained?  Are they computerized?

D   Are equipment lists available to all responders?

D   Are these lists  broken down into the various types of equipment (e.g., protec-
     tive clothing, monitoring instruments,  medical supplies, transportation  equip-
     ment)?

D   Is there a mechanism to ensure that the lists are kept up-to-date?

D   Have procedures necessary to obtain equipment on a 24-hour basis been identi-
     fied?

D   Does a program exist to carry out required maintenance of equipment?

D   Are there maintenance and repair records for each piece  of equipment?

D   Have mutual aid agreements  been established for the  use of  specialized re-
     sponse equipment?

D   Is sufficient communications equipment available for notifying  personnel or to
     transmit information?   Is the equipment of various participating  agencies com-
     patible?

D   Is transportation equipment available for moving equipment rapidly to the scene
     of an incident,  and its state of readiness assured?

Fac///f/es:
D   Have facilities capable of performing rapid chemical analyses been identified?

D   Do adequate facilities exist for storage and cleaning/reconditioning of response
     equipment?

D   Have locations  or facilities been identified for the storage, treatment, recycling,
     and disposal of wastes resulting from a release?

D   Do adequate facilities exist for carrying out training  programs?

D   Do facilities exist that are capable  of  providing medical treatment to persons
     injured by chemical exposure?

D   Have facilities  and procedures been  identified for housing  persons requiring
     evacuation or temporary relocation  as a result of an incident?

D   Have facilities been identified that are  suitable for command centers?
                                Page D-8

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C.2.6  Emergency Plan

The emergency plan, while it relates to many of the above criteria, also stands alone as a
means to assess preparedness at the State and local level of government,  and in the
private sector.  The following questions are directed more toward evaluating  the plan
rather than determining the preparedness level of the entity that has developed the plan.
It is not sufficient to ask if there is a plan, but rather to determine if the plan that does exist
adequately addresses the needs of the community or entity for which the plan was devel-
oped.

    D    Have the levels of vulnerability and probable locations of  hazardous materials
         incidents been identified in the plan?

    D    Have areas of public health concern been identified in the plan?

    D    Have sensitive environmental areas been  identified in the plan?

    D    For the hazardous materials identified in the area, does the plan include informa-
         tion  on the chemical and physical properties of  the materials, safety and emer-
         gency response information,  and hazard mitigation techniques? (NOTE:  It is not
         necessary that all this information  be included in the emergency plan;  the plan
         should, however, at least explain where such information is available.)

    D    Have all appropriate agencies,  departments, or organizations been involved in
         the process of developing or reviewing the plan?

    D    Have all  the appropriate agencies, departments, or organizations approved the
         plan?

    D    Has  the  organizational  structure and notification  list defined  in the plan  been
         reviewed in  the  last six months?

    D    Is the organizational structure identified in the plan compatible with the Federal
         response organization in the  NCR?

    D    Has  one organization been identified in the plan  as having command and control
         responsibility for the pre-response, response, and post response phases?

    D    Does the plan define the organizational  responsibilities and relationships among
         city, county, district,  State, and Federal response agencies?

    D    Are  all organizations that have a role in  hazardous materials response identified
         in the plan (public safety and health, occupational safety and health, transporta-
         tion, natural resources, environmental, enforcement, educational, planning, and
         private sector)?

    D    Are the procedures and contacts necessary to activate or deactivate the organi-
         zation clearly given in the  plan for the pre-response, response, and  post-re-
         sponse phases?

    D    Does the organizational structure outlined in the plan provide a  mechanism to
         review the activities conducted during a response or exercise to correct short-
         falls?

    D    Does the plan include a communications system/method to disseminate infor-
         mation to responders, affected public,  etc.?
                                     Page D-9

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D   Has a system been identified in the plan to carry out public information/commu-
     nity relations activities?

D   Has a central location or phone number been included in the plan for initial notifi-
     cation of an incident?

D   Have trained and equipped incident commanders been identified in the plan?

D   Does the plan include the authority for vesting site decisions in the incident com-
     mander?

D   Have government agency personnel that may be involved in response activities
     been involved in the planning process?

D   Have local private response organizations (e.g., chemical manufacturers, com-
     mercial cleanup contractors) that are available to assist during a response been
     identified in the plan?

D   Does the plan  provide for frequent training exercises to train personnel or to test
     the local contingency plans?

D   Are lists/systems that identify emergency equipment available to response  per-
     sonnel included in  the  plan?

D   Have locations of materials most likely to be used in mitigating the effects  of a
     release (e.g., foam, sand, lime) been identified in the plan?

D   Does the plan address the  potential needs for  evacuation,  what agency  is
     authorized to order or recommend  an evacuation, how it will be carried out, and
     where people  will be moved?

D   Has an emergency operating center, command center, or other central location
     with the  necessary communications capabilities been identified in the plan for
     coordination of emergency response activities?

D   Are there follow-up response activities scheduled in the plan?

D   Are there procedures for updating the plan?

D   Are there addenda provided with the plan, such as:  laws and ordinances, statu-
     tory responsibilities, evacuation plans, community relations plan, health plan,
     and resource  inventories (personnel, equipment, maps [not restricted to road
     maps],  and mutual aid agreements)?

D   Does the plan address the probable simultaneous occurrence of different types
     of emergencies (e.g.,  power outage and hazardous materials releases) and the
     presence of multiple hazards  (e.g., flammable and corrosive) during hazardous
     materials emergencies?
                                Page D-10

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                                 APPENDIX E

                              BIBLIOGRAPHY


General Emergency Planning for Hazardous Materials

American Institute of Chemical Engineers, Center for Chemical Plant Safety.  Guide-
lines for Hazard Evaluation Procedures.  Washington, DC:  A.I.Ch.E., 1985.

American Society of Testing & Materials.  Toxic and Hazardous Industrial Chemicals
Safety Manual.  1983.

Association of Bay Area Governments.  San Francisco Bay Area:  Hazardous Spill Pre-
vention and Response Plan. Volumes I & II.  Berkeley, CA:  1983.

Avoiding and Managing Environmental Damage from Major Industrial Accidents.  Proc.
of Conference of the  Air Pollution Control Association.  1985.

Bretherick, L.  Handbook of Reactive Chemical Hazards.   2nd ed.  Butterworth,  1979.

Brinsko, George A. et al.  Hazardous Material Spills and Responses for Municipalities.
(EPA-600/2-80-108, NTIS PB80-214141).  1980.

Cashman, John R. Hazardous Materials Emergencies:  Response and Control.  1983.

Chemical Manufacturers Association. Community Awareness and Emergency Response
Program Handbook.  Washington, DC: CMA, 1985.

Chemical Manufacturers Association. Community Emergency Response Exercise Pro-
gram. Washington, DC:  CMA, 1986.

Chemical Manufacturers Association. Risk Analysis in the Chemical Industry - Proceed-
ings of a Symposium.  Rockville, MD:  Government Institutes, Inc.,  1985.

Chemical Manufacturers Association. Site Emergency Response Planning.  Washington,
DC:  CMA, 1986.

      Copies of the CMA guides can be obtained by writing to:
           Publications Fulfillment
           Chemical Manufacturers Association
           2501 M Street, N.W.
           Washington,  D.C.  20037

Emergency Management and Civil Defense Division, Consolidated City of Indianapolis.
Final Report: Demonstration Project to Develop a Hazardous Materials Accident Preven-
tion and Emergency Response Program, Phases I, II,  III,  IV.  Indianapolis:  1983.

Energy Resources Co., Inc.; Cambridge Systematics,  Inc.; Massachusetts Department
of Environmental Quality Engineering.  Demonstration Project to Develop  a  Hazardous
Materials Accident Prevention and Emergency Response Program for the Commonwealth
of Massachusetts.  Volumes I & II.  Cambridge and Boston, MA:  1983.

Environmental and Safety Design, Inc.  Development of a Hazardous Materials Accident
Prevention and an Emergency Response Program.  Memphis, TN:  1983.
                                   Page E-l

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Federal Emergency Management Agency. Disaster Operations:  A Handbook for Local
Governments.  Washington, DC:  1981.

Federal Emergency Management Agency. Hazard Identification, Capability Assess-
ment, and Multi-Year Development Plan for Local Governments.  CPG 1-35, Washing-
ton, DC: 1985.

Federal Emergency Management Agency. Objectives for Local Emergency Manage-
ment.  CPG 1-5, Washington, DC:  1984.

Federal Emergency Management Agency. Professional Development Series:  Emer-
gency Planning — Student Manual.  Washington, DC.

Federal Emergency Management Agency. Professional Development Series:  Introduc-
tion to Emergency Management — Student Manual.  Washington, DC.

Gabor, T. and T.K. Griffith.  The Assessment of Community Vulnerability to Acute Haz-
ardous Materials Incidents.  Newark, DE:  University of Delaware, 1985.

Government Institutes, Inc. Md. R.C.R.A. Hazardous Waste Handbook.  Volumes 1  &  2.
1981.

Green, Don W., ed.  Perry's Chemical Engineers'Handbook.  6th ed.   McGraw-Hill,
1984.

Hawley, Gessner G., ed.  Condensed Chemical Dictionary.  10th ed.  New York:  Van
Nostrand Reinhold,  1981.

Hildebrand, Michael S.  Disaster Planning Guidelines for Fire Chiefs. Washington, DC:
International Association of Fire Chiefs, 1980.

Multnomah County Office of Emergency Management.  Hazardous  Materials Manage-
ment System: A Guide for Local Emergency Managers.  Portland, OR:  1983.

National Fire Protection Association.  Fire Protection Guide on Hazardous Materials.
Boston:  NFPA,  1986.

National Institute of Occupational Safety and Health.  Pocket Guide  to Chemical Haz-
ards.  Washington,  DC:  DHEW (NIOSH) 78-210, 1985.  (GPO Stock No.
017-033-00342-4)

New Orleans, City of.  Demonstration Project to  Develop a Hazardous Materials Acci-
dent Prevention and Emergency Response Program for the City of New Orleans, Phases
I, II, III, IV.  New Orleans:   1983.

Portland Office of Emergency Management.  Hazardous Materials Hazard Analysis.
Portland, OR: 1981.

Puget Sound Council of Governments.  Hazardous Materials Demonstration Project Re-
port:  Puget Sound Region.  Seattle, WA:  1981.

Sax, N. Irving. Dangerous Properties of Industrial Materials.  6th ed.  New York: Van
Nostrand Reinhold,  1984.

Sittig, Marshall.  Handbook of Toxic and Hazardous Chemicals and Carcinogens.
Noyes, 1985.

Smith,  Al J.  Managing Hazardous Substances Accidents.  1981.


                                    Page E-2

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U.S. Department of Transportation.  CHRIS: Manual I, A Condensed Guide to Chemical
Hazards.  U.S. Coast Guard, 1984.

U.S. Department of Transportation.  CHRIS:  Manual II, Hazardous Chemical Data.
U.S. Coast Guard, 1984.

U.S. Department of Transportation.  Emergency Response Guidebook.  Washington,
DC:  1984.

U.S. Environmental Protection Agency.  Community Relations in Superfund:  A  Hand-
book.  Washington, DC.

U.S. Environmental Protection Agency.  The National Oil and Hazardous Substances
Pollution Contingency Plan.  40 CFR 300.

Verschuaren, Karel.  Handbook of Environmental Data on Organic Chemicals. 2nd ed.
New York:  Van Nostrand Reinhold, 1983.

Waste Resource Associates, Inc.   Hazmat - Phases I, II, III,  IV: Demonstration Project
to Develop a Hazardous Materials Accident Prevention and Emergency Response Pro-
gram.  Niagara Falls, NY:   1983.

Zajic, J.E. and W.A.  Himmelman.  Highly Hazardous  Material Spills and Emergency
Planning.  Dekker,  1978.


Transportation  Emergency Planning

American Trucking Associations.  Handling Hazardous Materials.  Washington,  DC:
1980.

Association of American Railroads.  Emergency Action Guides.  Washington,  DC:  1984.

Association of American Railroads.  Emergency Handling of Hazardous  Materials in Sur-
face  Transportation.  Washington, DC:  1981.

Battelle Pacific Northwest  Laboratories.  Hazardous Material Transportation Risks In the
Puget Sound Region.  Seattle, WA:  1981.

Portland Office of  Emergency Management.  Establishing Routes for Trucks Hauling
Hazardous Materials:  The Experience In Portland, Oregon.  Portland, Oregon; 1984.

Portland Office of  Emergency Management.  Hazardous Materials Highway Routing
Study: Final Report.  Portland, OR: 1984.

Russell,  E.R., J.J. Smaltz, et al.  A Community  Model for Handling Hazardous Materi-
als Transportation  Emergencies: Executive Summaries. Washington, DC:  U.S.  Depart-
ment of Transportation, January 1986.

Russell,  E.R., J.J. Smaltz, et al.  Risk Assessment/Vulnerability Users Manual for Small
Communities and Rural Areas.  Washington,  DC: U.S. Department of Transportation,
March 1986.

Russell,  E.R., W. Brumgardt, et al. Risk Assessment/Vulnerability  Validation Study Vol-
ume 2: 11 Individual Studies.  Washington, DC:   U.S. Department  of Transportation,
June 1983.
                                    Page E-3

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Urban Consortium Transportation Task Force. Transportation of Hazardous Materials.
Washington, DC:  U.S. Department of Transportation, September 1980.

Urban Systems Associates, Inc., St. Bernard Parish Planning Commission.  Sf. Bernard
Parish:  Hazardous Materials Transportation and Storage Study.  New Orleans, LA:
1981.

Urganek, G. and E. Barber.  Development of Criteria to Designate Routes for Transporting
Hazardous Materials.  Springfield, VA:  National Technical Information Service, 1980.

U.S. Department of Transportation.  Community Teamwork: Working Together to Promote
Hazardous Materials Transportation Safety.  Washington, DC:  1983.

U.S. Department of Transportation.  A Guide  for Emergency Highway Traffic  Regulation.
Washington, DC:  1985.

U.S. Department of Transportation.  A Guide  to the Federal Hazardous Transportation
Regulatory Program.  Washington, DC:  1983.

U.S. Department of Transportation.  Guidelines  for Selecting Preferred Highway Routes for
Highway Route Controlled Quantity Shipments of Radioactive Materials.  Washington, DC:
1984.

U.S. Department of Transportation and U.S. Environmental Protection Agency.  Lessons
Learned from State and Local Experiences in Accident Prevention and Response Planning
for Hazardous Materials Transportation.  Washington, DC,  December 1985.

U.S. Department of Transportation.  Three-Phase/Four-Volume report:  Volume I, A
Community Model for Handling Hazardous Materials Transportation Emergencies;  Volume
II, Risk Assessment Users Manual for Small Communities and Rural Areas; Volume III,
Risk Assessment/Vulnerability Model Validation;  and,  Volume IV,  Manual for Small Towns
and  Rural Areas to Develop A Hazardous Materials Emergency Plan.   7/81 - 12/85. Docu-
ment is available to the U.S. Public through the National Technical Information Service,
Springfield, VA.  22161.

Transportation Research Board.  Transportation  of Hazardous Materials: Toward a National
Strategy.  Volumes 1 & 2. Washington, DC:  1983.


Spill Containment and Cleanup

Guswa,  J.H.  Groundwater Contamination and Emergency Response  Guide.  Noyes, 1984.

U.S. Environmental Protection Agency.  State Participation In the Superfund  Remedial Pro-
gram.  Washington, DC:  1984.


Personal Protection

International Association of Fire Chiefs.  Fire Service  Emergency Management Hand-
book. Washington, DC:   1985.

National Institute of Occupational  Safety and Health.  Occupational Safety and Health
Guidance Manual for Hazardous Waste Site Activities.  Washington, DC:  DHHS Publica-
tion No. 85-115, 1985.

U.S. EnvironrtSlfittil'^^ttion Agency.  Standard Operating Safety Guides.  Washing-
ton,  DC:  11
                                         E-4

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VIDEOTAPES

The following videotapes are available from the Chemical Manufacturers Association:

    D  CAER:   "Reaching Out"
    D  CAER:   "How a Coordinating Group Works"
    D  CAER:   "Working with the Media"
    D  CAER:   "Planning and Conducting Emergency Exercises"
    D  NCRIC:  "First on the Scene"

The following videotapes are available from FEMA's National Emergency Training Cen-
ter/Learning Resource Center/Emergency Management Information Center:

    D  "Livingston, LA, Hazardous Materials Spills" (September 28, 1982)
    D  "Waverly, TN,  Hazardous Materials Blast" (February 22, 1978)
Also available for purchase from FEMA's National Emergency Training Center (see p.
F-1 for address and telephone number) are videotapes of teleconferences produced
by FEMA's Emergency Education Network (EENET). One available teleconference is:

    D   "Emergency Exercises — Getting Involved in Community Preparedness," origi-
        nally seen on December  11, 1986, and co-sponsored by  FEMA, EPA, DOT/
        RSPA,  USCG, and CM A.
The following documentary videotape (produced by the League of Women Voters of
California and available from Bullfrog Films, Oley PA,  19547) provides public education
on the nature and need for local emergency planning and hazardous materials data
bases from a citizen's perspective.

    D  "Toxic Chemicals:  Information Is The Best Defense"
                                   Page E-5

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                               APPENDIX F

                   FEDERAL AGENCY ADDRESSES

                          1.  NATIONAL OFFICES
Federal Emergency Management Agency
Technological Hazards Division
Federal Center Plaza
500 C Street, S.W.
Washington.  DC 20472
(202) 646-2861

FEMA National Emergency Training Center
Emmitsburg, MD  21727
(301) 447-6771

U.S. Environmental Protection Agency
OSWER Preparedness Staff
401 M Street, S.W.
Washington,  DC 20460
(202) 475-8600
CEPP Hotline: 1-800-535-0202
(479-2449 in Washington, DC area)

U.S. Environmental Protection Agency
OERR Emergency Response Division
401 M Street, S.W.
Washington,  DC 20460
(202) 475-8720
Agency for Toxic Substances
and Disease Registry
Department of Health & Human Services
Chamblee Building 30S
Atlanta, GA 30333
(404) 452-4100
U.S. Department of Energy
1000 Independence Avenue, S.W.
Washington, DC 20585
(202) 252-5000
Department of Labor
Occupational Safety & Health Admin.
Directorate of Field Operations
200 Constitution Avenue, N.W.
Washington, DC  20210
(202) 523-7741
U.S. Coast Guard (G-MER)
Marine Environmental Response Division
2100 2nd Street, S.W.
Washington, DC 20593
(202) 267-2010 (info.)

NATIONAL RESPONSE CENTER:
1-800-424-8802
(202-426-2675 or 202-267-2675 in
Washington, DC area)

U.S. Dept. of Transportation
Research and Special Programs Admin.
Office of Hazardous Materials
Transportation (Attention:  DHM-50)
400 7th Street, S.W.
Washington, DC 20590
(202) 366-4000

Department of Justice
Environmental  Enforcement Section
Room 7313
10th and Constitution, N.W.
Washington, DC 20530
(202) 633-3646

Department of the Interior
18th and C St., N.W.
Washington, DC 20240
(202)343-3891
Department of Agriculture
Forest Service
P.O. Box 96090
Washington, DC  20013-6090
(703) 235-8019
                                 Page F-l

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Department of Commerce                 Department of State
NOAA — Superfund Program Coordinator    Office of Oceans and Polar Affairs
11400 Rockville Pike                       Room 5801
Rockville, MD  20852                      2201 C St., N.W.
(301) 443-8465                           Washington. DC 20520
                                        (202)  647-3263
Department of Defense
OASD (A+L)E                             Nuclear Regulatory Commision
Room 3D 833                             Washington, DC 20555
The Pentagon                             (301)  492-7000
Washington, DC  20301-8000
(202) 695-7820
                                  Page F-2

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             2.  REGIONAL OFFICES
EPA, FEMA, HHS, ATSDR, OSHA
Regional Offices	
U.S. COAST GUARD DISTRICTS
   Pacific Area  ;
 COMPACAREA/
  Atlantic Area
COMPLANTAREA
        /
 14th DUtrlct /
   •n.
    0

                                     •tt Quvd
                                     ldqu«rt«r«
                                        D.C.
                   Page F-3

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               REGIONAL OFFICES
 Department of Energy Regional
 Coordinating Offices for Radiological Assistance
 and Geographical Areas of Responsibility
       Alatk*

       101
United States Nuclear Regulatory Commission
                    Page F-4

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                           2.  REGIONAL  OFFICES
(Note:
                A.  EPA Regional Offices

Direct all requests to the  "EPA Regional Preparedness Coordinator" (RPC)
of the appropriate EPA Regional office.)
Region I
(Connecticut, Maine,  Massachusetts,
New Hampshire,  Rhode Island, Vermont)

John F. Kennedy Building, Rm. 2203
Boston, MA  02203
(617) 565-3715
RPC:  (617) 861-6700
Region II
(New Jersey, New York, Puerto Rico,
Virgin Islands)

26 Federal Plaza, Room 900
New York, NY  10278
(212) 264-2525
RPC:  (201) 321-6657
Region III
(Delaware, Washington DC, Maryland,
Pennsylvania, Virginia, West Virginia)

841 Chestnut Street
Philadelphia, PA  19107
(215) 597-9800
RPC:  (215) 597-8907
                               Region VI
                               (Arkansas, Louisiana,  New Mexico,
                               Oklahoma, Texas)

                               1445  Ross Avenue, 12th Floor
                               Dallas, TX 75202-2733
                               (214) 655-6444
                               RPC: (214) 655-2270


                               Region VII
                               (Iowa, Kansas, Missouri, Nebraska)

                               726 Minnesota Avenue
                               Kansas City, KS  66101
                               (913) 236-2800
                               RPC: (913) 236-2806


                               Region VIII
                               (Colorado, Montana, North Dakota,
                               South Dakota, Utah, Wyoming)

                               One Denver Place
                               999 18th Street,  Suite 1300
                               Denver, CO 80202-2413
                               (303) 293-1603
                               RPC: (303) 293-1723
Region IV
(Alabama, Florida, Georgia, Kentucky,
Mississippi, North Carolina,
South Carolina,  Tennessee)

345 Courtland, Street, N.E.
Atlanta,  GA  30365
(404)  347-4727
RPC:  (404) 347-3931
Region V
(Illinois,  Indiana, Michigan,
Minnesota, Ohio, Wisconsin)

230 S. Dearborn Street
Chicago, IL  60604
(312)  353-2000
RPC:  (312) 886-1964
                               Region IX
                               (Arizona, California, Hawaii, Nevada,
                               American Samoa, Guam)

                               215 Fremont Street
                               San Francisco, CA  94105
                               (415) 974-8071
                               RPC: (415) 974-7460
                               Region X
                               (Alaska, Idaho, Oregon,  Washington)

                               1200 6th Avenue
                               Seattle, WA 98101
                               (206) 442-5810
                               RPC: (206) 442-1263
                                   Page F-5

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                          S.  FEMA Regional Offices
 (Note:     Direct all requests to the "Hazmat Program Staff" of the appropriate FEMA
           Regional office.)
Region I
(Connecticut, Maine, Massachusetts,
New Hampshire, Rhode Island,  Vermont)

442 J.W. McCormack POCH
Boston, MA  02109
(617) 223-9540

Region II
(New Jersey, New York, Puerto Rico,
Virgin Islands)

Room 1337
26 Federal Plaza
New York, NY  10278
(212) 264-8980
Region III
(Delaware, Washington  DC, Maryland,
Pennsylvania, Virginia, West Virginia)

Liberty Square Building
105 S. 7th Street
Philadelphia, PA  19106
(215) 597-9416
Region IV
(Alabama, Florida, Georgia, Kentucky,
Mississippi, North Carolina,
South Carolina,  Tennessee)

Suite 700
1371 Peachtree Street,  N.E.
Atlanta, GA  30309
(404) 347-2400
Region V
(Illinois, Indiana,  Michigan,
Minnesota, Ohio, Wisconsin)

24th Floor
300 S. Wacker Drive
Chicago, IL  60606
(312) 353-8661
Region VI
(Arkansas, Louisiana, New Mexico,
Oklahoma, Texas)

Federal Regional Center, Room 206
800 N. Loop 288
Denton, TX  76201-3698
(817) 387-5811
Region VII
(Iowa, Kansas, Missouri, Nebraska)
911 Walnut Street,  Room 300
Kansas City, MO 64106
(816) 374-5912

Region VIII
(Colorado,  Montana, North Dakota,
South Dakota, Utah, Wyoming)

Denver Federal Center, Building 710
Box 25267
Denver. CO 80225-0267
(303) 235-4811
Region IX
(Arizona, California, Hawaii, Nevada,
American Samoa, Guam)
Building 105
Presidio of San Francisco, CA  94129
(415)  923-7000

Region X
(Alaska, Idaho, Oregon, Washington)
Federal Regional Center
130 228th St.,  S.W.
Bothell, WA  98021-9796
(206) 481-8800
                                   Page F-6

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                     C.  HHS REGIONAL OFFICES
(Note:  Consult the map on Page F-3 to determine which States are assigned to each
Region.)
Region I
Division of Preventive Health Services
John Fitzgerald Kennedy Building
Boston, Massachusetts  02203
(617) 223-4045
Region II
Division of Preventive Health Services
Federal Building
26 Federal Plaza, Room 3337
New York, New York  10278
(212) 264-2485
Region III
Division of Preventive Health Services
Gateway Building #1
Post Office Box 13716
Philadelphia, Pennsylvania  19101
(215) 596-6650
Region IV
Division of Preventive Health Services
101 Marietta Tower
Atlanta, Georgia 30323
(404) 331-2313
Region V
Division of Preventive Health Services
300 South Wacker Drive
Chicago, Illinois  60606
(312) 353-3652
Region VI
Division of Preventive Health Services
1200 Main Tower Building, Room 1835
Dallas, Texas  75202
(214) 767-3916
Region VII
Division of Preventive Health Services
601 East 12th Street
Kansas City, Missouri 64106
(816) 374-3491

Region VIII
Division of Preventive Health Services
1185 Federal Building
1961 Stout Street
Denver, Colorado  80294
(303) 844-6166, ext.  28
Region IX
Division of Preventive Health Services
50 United Nations Plaza
San Francisco, California 94102
(415) 556-2219
Region X
Division of Preventive Health Services
2901 Third Avenue, M.S. 402
Seattle, Washington  98121
(206) 442-0502
                                    Page F-7

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           D. ATSDR PUBLIC HEALTH ADVISORS ASSIGNED TO
                        EPA REGIONAL OFFICES

(Note:  Consult the map on Page F-3 to determine which States are assigned to each
Region.)
Region I
ATSDR Public Health Advisor
EPA Superfund Office
Room 1903
John F. Kennedy Building
Boston, MA  02203
(617)861-6700
Region II
ATSDR Public Health Advisor
Emergency & Remedial Response
Room 737
26 Federal Plaza
New York, New York 10007
(212)  264-8676
Region III
ATSDR Public Health Advisor
EPA Superfund Office
841 Chestnut Street, 6th Floor
Philadelphia, PA  19106
(215)  597-7291
Region IV
ATSDR Public Health Advisor
Air & Waste Management Division
345 Courtland Street, N.E.
Atlanta, GA  30365
(404)  347-3931/2
Region V
ATSDR Public Health Advisor
Emergency & Remedial Branch (5HR)
230 S. Dearborn
Chicago, IL  60604
(312)  886-9293
Region VI
ATSDR Public Health Advisor
EPA Superfund Office
1201 Elm Street
Dallas, TX 75270
(214)  767-9872

Region VII
ATSDR Public Health Advisor
Waste Management Branch
726 Minnesota Avenue
Kansas City,  KS 66101
(913)  236-2856

Region VIII
ATSDR Public Health Advisor
Waste Management Division
1860 Lincoln  Street
Denver, CO  80295
(303)  293-1526
Region IX
ATSDR Public Health Advisor
Toxics & Waste Management Division
215 Freemont Street
San Francisco, CA  94105
(415)  974-7742
Mailing address: P.O. Box 2453
Daly City, CA 94017
Region X
ATSDR Public Health Advisor
Hazardous Waste (M/S 525)
1200 6th  Avenue
Seattle, WA  98101
(206)  442-2711
                                  Page F-8

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                    E.  OSHA REGIONAL OFFICES
(Note:  Consult the map on Page F-3 to determine which States are assigned to each
Region.)
Region I
16-18 North Street - 4th Floor
1 Dock Square Building
Boston,  Massachusetts 02109
(617) 223-6710
Region II
1515 Broadway (1 Astor Plaza)
Room 3445
New York, New York  10036
(212) 944-3432
Region III
Gateway Building - Suite 2100
3535 Market Street
Philadelphia, Pennsylvania  19104
(215) 596-1201
Region IV
1375 Peachtree Street, N.E.
Suite 587
Atlanta,  Georgia  30367
(404) 347-3573

Region V
32nd Floor - Room 3244
230 Dearborn Street
Chicago, Illinois   60604
(312) 353-2220
Region VI
525 Griffin Street
Room 602
Dallas, Texas 75202
(214) 767-4731
Region VII
911 Walnut Street
Room 406
Kansas City, Missouri  64106
(816) 374-5861
Region VIII
Federal Building - Room 1576
1961 Stout Street
Denver, Colorado 80294
(303) 844-3061
Region IX
11349 Federal Building
450 Golden Gate Avenue
P.O. Box 36017
San Francisco, California  94102
(415) 556-7260
Region X
Federal Office Building
Room 6003
909 First Avenue
Seattle, Washington 98174
(206) 442-5930
                                   Page F-9

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                     F.  U.S.  Coast Guard District Offices
1st District
(Maine, Massachusetts, New York,
New Hampshire,  Connecticut,
Rhode Island, Vermont, Northern
Pennsylvania, Northern New Jersey)

Commander (mep)
408 Atlantic Avenue
Boston, MA  02110-2209
(617) 223-8444
7th District
(Georgia, Florida, South Carolina,
Puerto Rico, Virgin Islands)

Commander (mep)
Federal Building
51 S.W. 1st Avenue
Miami, FL 33130
(305) 350-5276
2nd District
(Alabama, Arkansas, Colorado, Illinois,
Indiana, Iowa, Kansas, Kentucky,
Minnesota, Mississippi, Missouri,
Nebraska, North Dakota, Ohio,
Western Pennsylvania,
South Dakota, Tennessee
West Virginia, Wyoming)
8th District
(Alabama, Florida, Georgia, Louisiana,
Mississippi, New Mexico, Texas)

Commander (mpes)
Hale Boggs Federal Building
500 Camp Street,
New Orleans, LA 70130
(504) 589-6296
Commander (meps)
1430 Olive Street
St. Louis, MO  63103
(314)  425-4655
9th District
(Indiana, Illinois, Michigan, Minnesota,
Ohio,  Pennsylvania, New York,
Wisconsin
5th District
(Maryland, Delaware, North Carolina,
Southern Pennsylvania,
Southern New Jersey, Virginia)

Commander (mep)
Federal Building
431 Crawford Street
Portsmouth,  VA  23705
(804) 398-6638
Commander (mep)
1240 East 9th Street
Cleveland, OH 44199
(216)  522-3918

11th District
(Arizona, California, Nevada, Utah)

Commander (mep)
Union Bank Building
400  Oceangate
Long Beach, CA 90822
(213)  590-2301
                                   Page F-10

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              F.  U.S.  Coast Guard District Offices (Continued)
13th District
(Idaho, Montana, Oregon, Washington)

Commander (mep)
Federal Building
915 Second Avenue
Seattle, WA  98174
(206) 442-5850
14th District
(Hawaii, Guam, American Samoa,
Trust Territory of the Pacific Island,Com
monwealth of Northern Mariana Islands)

Commander (mep)
Prince Kalanianaole Federal Building
300 Ala Moana Boulevard, 9th Floor
Honolulu, HI  96850
(808)541-2114
17th District
(Alaska)

Commander (mep)
P.O. Box 3-5000
Juneau, AK  99802
(907) 586-7195
                                  Page F-ll

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     G.  Department of Energy (DOE) Regional Coordinating Offices For
                  Radiological Emergency Assistance Only
Region 1
(Connecticut, Delaware, District of
Columbia, Maine,  Maryland,
Massachusetts, New Hampshire, New
Jersey, New York, Pennsylvania,
Rhode Island, Vermont)

Brookhaven Area Office:
Upton, NY  11973
(516) 282-2200
FTS - 666-2200
(312) 972-5731 (off hours)
(Use same 7-digit number for FTS)
Region 2
(Arkansas, Kentucky, Louisiana,
Mississippi, Missouri, Puerto Rico,
Tennessee, Virgin Islands, Virginia,
West Virginia)

Oak Ridge Operations Office:
P.O. Box E
Oak Ridge, TN 37830
(615) 576-1005
FTS 626-1005
Region 3
(Alabama, Canal Zone, Florida,
Georgia, North Carolina,
South Carolina)

Savannah  River Operations Office:
P.O. Box A
Aiken, SC  29801
(803)  725-3333
FTS - 239-3333
Region 4
(Arizona, Kansas,  New Mexico,
Oklahoma, Texas)

Albuquerque Operations Office:
P.O.  Box 5400
Albuquerque, NM  87115
(505)  844-4667
(Use same 7-digit number for FTS)
Region 5
(Illinois,  Indiana, Iowa, Michigan,
Minnesota, Nebraska, North Dakota,
Ohio, Sourth Dakota,  Wisconsin)

Chicago Operations Office:
9800 South Cass Avenue
Argonne, IL  60439
(312) 972-4800 (duty hours)
(Use same 7-digit number for FTS)
(312) 972-5731 (off hours)
Region 6
(Colorado, Idaho,  Montana, Utah,
Wyoming)

Idaho Operations Office:
550 Second Street
Idaho Falls, ID 83401
(208) 526-1515
FTS 582-1515
Region 7
(California,  Hawaii, Nevada)

San Francisco Operations Office:
1333 Broadway
Oakland, CA 94612
(415)  273-4237
FTS 537-4237
Region 8
(Alaska, Oregon, Washington)

Richland Operations Office:
P.O. Box 550
Richland, WA 99352
(509) 373-3800
FTS - 440-3800
                                  Page F-12

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        H.  Department Of Transportation, Regional Pipeline Offices
Office of Pipeline Safety
Eastern Region, DPS-4, Room 8321
400 7th  Street, S.W.
Washington, DC   20590
(202) 366-4585

(Connecticut, Delaware, District of
Columbia, Maine, Maryland, Vermont,
Massachusetts, New Hampshire, New
Jersey, New York,  Pennsylvania,
Rhode Island, Virginia, West Virginia,
Puerto Rico)
Office of Pipeline Safety
Southeast Region, DPS-7
2320 La Branch,  Room 2116
Houston, Texas  77704
(713)  750-1746

(Arkansas, Louisiana,  New Mexico,
Oklahoma, Texas)

Office of Pipeline Safety
Western Region,  DPS-8
555 Zang  Street, 2nd  Floor
Lakewood, Colorado  80228
(303)  235-3424
Office of Pipeline Safety
Southern Region, DPS-5, Ste. 504N.
1720 Peachtree Road, N.W.
Atlanta, Georgia 30309
(404) 347-2632

(Alabama, Florida,  Georgia, Kentucky,
 North Carolina, South Carolina, Tennessee)
(Arizona, California, Colorado, Idaho,
Montana, Nevada, North Dakota, Oregon,
South Dakota, Utah, Washington,
Wyoming, Alaska, Hawaii)
Office Of Pipeline Safety
Central Region, DPS-6
911 Walnut Street,  Room 1811
Kansas City, Missouri  64106
(816) 374-2653

(Iowa, Illinois, Indiana, Kansas,  Michigan,
Minnesota,  Ohio, Missouri, Nebraska,
Wisconsin)
                                   Page F-13

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           /. U.S. Nuclear Regulatory Commission Regional Offices
Region 1
(Connecticut, Delaware, District of
Columbia, Maine, Maryland,
Massachusetts, New Hampshire, New
Jersey, New York, Pennsylvania,
Rhode Island, Vermont)

USNRC
631 Park Avenue
King of Prussia, PA 19406
(215) 337-5000

Region 2
(Alabama, Florida, Georgia, Kentucky,
Mississippi, North Carolina, Puerto Rico,
South Carolina, Tennessee, Virginia,
Virgin Islands, West Virginia)
Region 4
(Arkansas, Colorado, Idaho,  Kansas,
Louisiana, Montana, Nebraska, New
Mexico, North Dakota, Oklahoma,
South Dakota, Texas, Utah, Wyoming)
USNRC
Suite 1000
611 Ryan Plaza Drive
Arlington,  TX  76011
(817)  860-8100

Region 5
(Alaska, Arizona, California,
Hawaii, Nevada, Oregon, Pacific
Trust Territories, Washington)
USNRC
Suite 2900
101 Marietta Street, NW
Atlanta, GA  30323
(404)  331-4503
Region 3
(Illinois, Indiana, Iowa, Michigan,
Minnesota, Missouri, Ohio, Wisconsin)

USNRC
799 Roosevelt Road
Glen Ellyn, IL 60137
(312)  790-5500
USNRC
Suite 210
1450 Maria Lane
Walnut Creek, CA 94596
(415)943-3700
                                   Page F-14   .  4U-S. Q.P.O. 1987-716-002160587

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