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-
dentsboth at fixed facilities (manufac-
turing, processing, storage, and disposal)
and during transportation (highways, wa-
terways, rail, and air). Plans for respond-
ing to radiological incidents and natural
emergencies such as hurricanes, floods,
and earthquakes are not the focus of this
guidance, although most aspects of plan
development and appraisal are common
to these emergencies. Communities
should see NUREG 0654/FEMA-REP-1
and/or FEMA-REP-5 for assistance in ra-
diological planning. (See Appendix C.)
Communities should be prepared, how-
ever, for the possibility that natural emer-
gencies, radiological incidents, and haz-
ardous materials incidents will cause or
reinforce each other.
The objectives of this guide are to:
D Focus community activity on
emergency preparedness and
response;
D Provide communities with infor-
mation useful in organizing the
planning task;
D Furnish criteria to determine risk
and to help communities decide
whether they need to plan for
hazardous materials incidents;
D Help communities conduct plan-
ning that is consistent with their
needs and capabilities; and
D Provide a method for continually
updating a community's emer-
gency plan.
This guide will not:
D Give a simple "fill-in-the-
blanks" model plan (because
each community needs an
emergency plan suited to its own
unique circumstances);
D Provide details on response
techniques; or
D Train personnel to respond to in-
cidents.
Community planners will need to consult
other resources in addition to this guide.
Related programs and materials are dis-
cussed in Section 1.5.
1.3 How to Use This Guide
This guide has been designed so it can be
used easily by both those communities
with little or no planning experience and
those communities with extensive plan-
ning experience.
All planners should consult the decision
tree in Exhibit 1 for assistance in using this
guide.
Chapter 2 describes how communities
can organize a planning team. Communi-
ties that are beginning the emergency
planning process for the first time will
need to follow Chapter 2 very closely in
order to organize their efforts effectively.
Communities with an active planning
agency might briefly review Chapter 2, es-
pecially to be sure that all of the proper
people are included in the planning proc-
ess, and move on to Chapter 3 for a de-
tailed discussion of tasks for hazardous
materials planning. Planners should re-
view existing emergency plans, perform a
hazards identification and analysis, assess
prevention and response capabilities, and
then write or revise an emergency plan.
Page 2
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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)
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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
Page 5
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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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Page 10
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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
Page 11
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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.
Page 12
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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-
Page 14
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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.
Page 15
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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.
Page 16
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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:
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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.
-------
Exhibit 3 (Continued)
EXAMPLE HAZARDS ANALYSIS FOR A HYPOTHETICAL COMMUNITY
Hazard A
Hazard B
Hazard C
3. RISK ANALYSIS
a. Probability of
hazard occurrence
Low because chlorine is stored in an
area with leak detection equipment in 24
hour service with alarms. Protective
equipment is kept outside storage room.
High Highway Interchange has a his-
tory of accidents due to poor visibility of
exits and entrances.
Low facility has up to date contain-
ment facilities with leak detection
equipment, and an emergency plan for
its employees. There are good security
arrangements that would deter tamper-
Ing or accidents resulting from civil up-
risings.
b.
Consequences If
people are exposed
High levels of chlorine gas in the nursing
home and factory could cause death and
respiratory distress. Bedridden nursing
home patients are especially suscepti-
ble.
Release of vapors and subsequent fire
may cause traffic accidents. Injured
and trapped motorists are subject to le-
thal vapors and possible Incineration.
Windblown vapors can cause respiratory
distress for nearby residents and busi-
ness patrons.
If accident occurs while school Is In ses-
sion, children could be killed, blinded,
and/or suffer chronic debilitating respi-
ratory problems. Plant workers would
be subject to similar effects at any
time.
a
00
X)
d.
Consequences for
property
Consequences of
environmental
exposure
Possible superficial damage to facility
equipment and structures from corrosive
fumes (repairable).
Possible destruction
fauna and flora.
of surrounding
Repairable damage to highway. Poten-
tial destruction of nearby vehicles due to
fire or explosions.
Potential for fire damage to adjacent
forest preserve due to combustible ma-
terial (recoverable in the long term).
Vapors may explode In a confined space
causing property damage (repairable).
Damage could result from fires (repair-
able).
Farm animals and other fauna could be
killed or suffer health effects necessi-
tating their destruction or indirectly
causing death.
Probability of
simultaneous
emergencies
Low
High
Low
f. Unusual
environmental
conditions
None
Hilly terrain prone to mists, thus creat-
ing adverse driving conditions.
Located In a 500 year river flood plan.
-------
D The level of detail that is necessary;
D The types of response to emphasize; and
D Priority hazards or areas for planning.
The examples presented in Exhibit 3 illustrate the basic fact that there are no hard and fast
rules for weighing the relative importance of different types of hazards in the context of
the planning process. Compare example hazards B and C in the exhibit. Hazard C
involves a substance, methyl isocyanate (MIC), whose lethal and severe chronic effects
were evident at Bhopal. As described in the example, an MIC release could affect 200
plant workers and 1000 children in a nearby school. By contrast, the ammonia in example
hazard B is less lethal than MIC and threatens fewer people. With just this information in
mind, a planner might be expected to assign the MIC a higher planning priority than he
would the ammonia. Consider now the "probability of occurrence." In example C, plant
safety and prevention measures are excellent, and an MIC incident is correspondingly
unlikely to occur. On the other hand, poor highway construction and weather conditions
that affect visibility make an ammonia incident (example hazard B) far more probable.
Planners must balance all factors when deciding whether to give planning priority to B or
C. Both situations are dangerous and require emergency planning. Some would argue
that the lethality of MIC outweighs the presence of good safety and prevention proce-
dures; others would argue that the frequency of highway interchange accidents is reason
enough to place greater emphasis on planning to deal with an ammonia incident. Each
planning team must make such judgments on priorities in light of local circumstances.
Before initiating plan development, the planning team should complete an assessment of
available response resources, including capabilities provided through mutual aid agree-
ments. Guidance for conducting such an assessment is presented in the following sec-
tion.
3.4 Capability Assessment
This section contains sample questions to help the planning team evaluate preparedness,
prevention, and response resources and capabilities. The section is divided into three
parts. The first part covers questions that the planning team can ask a technical repre-
sentative from a facility that may need an emergency plan. The second part includes
questions related to transportation.
The third part addresses questions to a variety of response and government agencies,
and is designed to help identify all resources within a community. This information will
provide direct input into the development of the hazardous materials emergency plan and
will assist the planning team in evaluating what additional emergency response resources
may be needed by the community.
3.4.1 Facility Resources
What is the status of the safety plan (also referred to as an emergency or contingency
plan) for the facility? Is the safety plan consistent- with any community emergency plan?
D Is there a list of potentially toxic chemicals available? What are their physical
and chemical characteristics, potential for causing adverse health effects, con-
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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?
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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?
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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?
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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-
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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.
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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.
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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.
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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
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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.
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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.
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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.
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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-
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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.
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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.)
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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?
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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
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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?
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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?
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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?
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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
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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?
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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.?
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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 /
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0
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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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