Hazardous Materials Emergency
Planning Guide
(Proposed)
November 1936
NATIONAL RESPONSE TEAM
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The National Response Team (NRT) composed of 14 Federal agencies
having major responsibilities in environmental, transportation, and public health
areas is the national body for planning, preparedness, and response actions
related to oil discharges and hazardous substance releases.
The NRT is responsible for publishing guidance documents for the preparation
and implementation of hazardous substance emergency plans.
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.
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Hazardous Materials Emergency
Planning Guide
(Proposed)
November 1986
NATIONAL RESPONSE TEAM
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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 into
the air.
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 devel-
oping their own plan, and by emergency
planning committees formed in accord
with the "Emergency Planning and Com-
munity Right-to-Know Act of 1986." In-
formation 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:
~ 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);
~ The level of danger (small com-
munities are sometimes sur-
rounded by large industry); and
~ 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.
Many government 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.
i
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The Background of this Guidance
This Hazmat Emergency Planning Guide
has been developed cooperatively by sev-
eral Federal agencies. It is being pub-
lished by the National Response Team in
compliance with Section 303(f) of the
"Emergency Planning and Community
Right-to-Know Act of 1986," Title III of
the "Superfund 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). Two draft revi-
sions of FEMAtIO were circulated in 1985;
this guide, although significantly different
in format, is responsive to comments on
the two earlier drafts.
The U.S. Environmental Protection
Agency (EPA) published interim guidance
for its Chemical Emergency Preparedness
Program (CEPP) late in 1985 and invited
public comment. This hazardous materi-
als planning guide incorporates material
from Chapters 2 ("Organizing the Com-
munity"), 4 ("Contingency Plan Develop-
ment and Content"), and 5 ("Contingency
Plan Appraisal and Continuing Planning")
of the interim CEPP guidance and is re-
sponsive to comments on those sections
of the interim CEPP guidance. EPA is re-
vising and updating CEPP technical guid-
ance materials that will include site-spe-
cific guidance, criteria for identifying
acutely toxic chemicals, and chemical
profiles and list. Planners should use this
general planning guide in conjunction with
the CEPP materials.
Commenters on the earlier draft revisions
of FEMA-10 and the interim CEPP guid-
ance noted a need for further information
about occupational safety and health as
well as threats to general health from haz-
ardous materials incidents. The U.S. Oc-
cupational Safety and Health Administra-
tion (OSHA) and the U.S. Agency for
Toxic Substances and Disease Registry
(ATSDR) have assisted in preparing this
general planning guide.
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.
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). 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 a single-haz-
ard hazardous materials emergency plan,
if a community does not have the re-
sources 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."
The NCP very carefully defines "hazard-
ous substances." This guide will consis-
tently use "hazardous materials" to in-
clude "hazardous substances," petro-
leum, natural gas, synthetic gas, acutely
toxic chemicals, and other toxic chemi-
cals.
Finally, this general planning guide was
prepared at the same time as the U.S.
Congress debated SARA, and was pub-
lished soon after SARA became law. The
final form of this guide will be adjusted to
reflect relevant provisions of SARA.
ii
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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 7
1.5 Related Programs and Materials 7
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 8
1.5.4 Chemical Manufacturers Association's Community Awareness
and Emergency Response Program (CMA/CAER) 9
CHAPTER 2: SELECTING AND ORGANIZING THE PLANNING TEAM 10
2.1 Introduction 10
2.2 The Planning Team 10
2.2.1 Forming the Planning Team 10
2.2.2 Composition of the Team 11
2.2.3 Respect for All Legitimate Interests 11
2.2.4 Special Importance of Local Governments 13
2.2.5 Local Industry Involvement 13
2.2.6 Size of Planning Team 13
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 15
2.4 Beginning to Plan 17
CHAPTER 3: TASKS OF THE PLANNING TEAM 18
3.1 Introduction 18
3.2 Review of Existing Plans 18
3.3 Hazards Analysis 19
3.3.1 Developing the Hazards Analysis 20
3.3.2 Obtaining Facility Information 23
3.3.3 Example Hazards Analysis 24
3.4 Capability Assessment 24
3.4.1 Facility Resources 27
3.4.2 Transporter Resources 28
3.4.3 Community Resources 29
3.5 Writing an Emergency Plan 32
CHAPTER 4: DEVELOPING THE PLAN 33
4.1 Introduction 33
4.2 Hazardous Materials Appendix to Multi-Hazard EOP 33
4.3 Single-Hazard Emergency Plan 34
CHAPTER 5: HAZARDOUS MATERIALS PLANNING ELEMENTS 37
5.1 Introduction 37
5.2 Discussion of Planning Elements 38
CHAPTER 6: PLAN APPRAISAL AND CONTINUING PLANNING 63
6.1 Introduction 63
6.2 Plan Review and Approval 63
6.2.1 Internal Review 63
6.2.2 External Review 63
6.3 Keeping the Plan Up-to-Date 65
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TABLE OF CONTENTS (Continued)
PAGE
6.4 Continuing Planning
66
6.4.1 Exercises
66
6.4.2 Incident Review
67
6.4.3 Training
67
APPENDIX A: LIST OF ACRONYMS
APPENDIX B: GLOSSARY
APPENDIX C: CRITERIA FOR ASSESSING STATE AND LOCAL PREPAREDNESS
APPENDIX D: BIBLIOGRAPHY
APPENDIX E: FEDERAL AGENCY ADDRESSES
EXHIBITS
Exhibit 1: Overview of Planning Process 3
Exhibit 2: Potential Groups and Agencies for an Emergency Planning Team 12
Exhibit 3: Example Hazards Analysis for a Hypothetical Community 25
Exhibit 4: Sample Outline of a Hazardous Materials Emergency Plan 35
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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., train derailments, indus-
trial incidents) happening in their commu-
nities. Recent evidence shows that haz-
ardous materials incidents are considered
by many to be the most significant threat
facing local jurisdictions. Ninety-three
percent 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
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 communities with limited
resources 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
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.
companies can use this guidance to coor-
dinate their own hazardous materials
emergency planning with that of the local
community.
"Hazardous materials" refers to "hazard-
ous substances," petroleum, natural gas,
synthetic gas, acutely toxic chemicals,
and other toxic chemicals. This guidance
deals specifically with response to hazard-
ous materials incidents both at fixed fa-
cilities (manufacturing, processing, stor-
age, disposal) and during transportation
(highways, waterways, rail, and air).
Plans for responding to natural emergen-
1.2 Purpose of this Guide
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cies such as hurricanes, floods, and
earthquakes are not the focus of this guid-
ance, although most aspects of plan de-
velopment and appraisal are common to
these emergencies. This guide does not
address planning for radiological inci-
dents; communities should see NUREG
0654/FEMA REP-1 and/or FEMA's REP-5
for assistance in radiological planning.
(See Appendix B.) Communities should
be prepared, however, for the possibility
that natural emergencies, radiological in-
cidents, and hazardous materials inci-
dents will cause or reinforce each other.
The objectives of this guide are to:
~ Focus community activity on
emergency preparedness and
response;
~ Provide communities with infor-
mation useful in organizing the
planning task;
~ Furnish criteria to determine risk
and to help communities decide
whether they need to plan for
hazardous materials incidents;
~ Help communities conduct plan-
ning that is consistent with their
needs and capabilities; and
~ Provide a method for continually
updating a community's emer-
gency plan.
This guide will not:
~ Give a simple ** fillinthe
blanks" model plan (because
each community needs an
emergency plan suited to its own
unique circumstances);
~ Provide details on response
techniques; or _
~ 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.
Chapter 4 discusses two basic ap-
proaches to writing an emergency plan:
(a) developing or revising a hazardous
materials appendix to a multi-hazard
emergency operations plan (EOP) (see
Section 1.5.1); and (b) developing or re-
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Exhibit 1
OVERVIEW OF PLANNING PROCESS
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vising a single-hazard hazardous materi-
als plan. Developing a hazardous materi-
als appendix as part of a multi-hazards
approach is preferable. Some communi-
ties, however, have neither the capability
nor resources to do this immediately.
Communities that choose to develop or
revise an EOP should consult FEMA's CPG
1 -8 for specific structure requirements for
the plan in addition to the discussion in
Section 1.5.1. Communities that choose
to develop or revise a single-hazard plan
for hazardous materials can use the sam-
ple outline of an emergency plan in Chap-
ter 4 to organize the various hazardous
materials planning elements.
Chapter 5 describes the elements to be
considered when planning for potential
hazardous materials incidents. All com-
munities (both those preparing an EOP 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 list of acronyms used in
this guidance. Appendix B is a glossary of
terms used throughout this guide. (Be-
cause this guide necessarily contains
many acronyms and technical phrases,
local planners should regularly consult
Appendices A and B.) Appendix C con-
tains 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, organizational
structure, communication systems, re-
sources, and the completed emergency
plan. Appendix D is a list of references on
various topics addressed in this guidance.
Appendix E is a listing of addresses of
Federal agencies at the national and Re-
gional 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 in 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, and public
health responsibilities, is responsible for
emergency preparedness and planning on
a nationwide basis.
A key element of Federal support during
hazardous materials transportation and
fixed facility incidents is a response by
U.S. Coast Guard (USCG) or Environ-
mental Protection Agency (EPA) On-
Scene Coordinators (OSCs) and, through
the OSC, to local responders. These
OSCs are supplemented by Federal Re-
gional Response Teams (RRTs) that are
available to provide advice, support, and
assistance to the OSC and, through the
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OSC, to local responders. Federal re-
sponses may be triggered by a report to
the National Response Center (NRC), op-
erated by the Coast Guard. Provisions of
the Federal Water Pollution Control Act
(Clean Water Act), CERCLA, and various
other Federal laws require persons re-
sponsible for a discharge or release to no-
tify the NRC immediately. The NRC Duty
Officer promptly relays each report to the
appropriate Coast Guard or EPA OSC, de-
pending on the location of an incident.
Based on this initial report and any other
information that can be obtained, the OSC
makes a preliminary 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 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, or the response is be-
yond the capability of State and local gov-
ernments, the OSC may initiate Federal
actions. The Coast Guard has OSCs at 48
locations (zones) in 12 districts, and the
EPA has OSCs in its 10 Regional offices
and in certain EPA field offices. (See Ap-
pendix E 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.
NRT efforts to make the RRTs more visible
and effective coordinators of prepared-
ness activities could assist local commu-
nity planning efforts. Appendix C of this
guide contains an adaptation of extensive
criteria developed by the NRT Prepared-
ness 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.
^ B. 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").
Title III of SARA requires the establish-
ment of State commissions, planning dis-
tricts, and local 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
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:
~ Elected State and local officials;
~ Law enforcement, civil defense,
firefighting. first aid, health, local
environmental, hospital, and
transportation personnel;
~ Broadcast and print media;
~ Community groups; and
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~ 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. The
owner or operator of each facility subject
to these requirements must notify the ap-
propriate State emergency response
commission that the facility 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
adequate information is available for the
planning committee to know which facili-
ties to plan around. When there is a re-
lease 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 emergency planning committee for
each area likely to be affected by the re-
lease, and the State emergency planning
commission of any State likely to be af-
fected by the release.
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
schedules for response practice drills.
(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,
upon request, 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.)
To ensure that information is available for
developing emergency plans and assisting
in response activities, facility owners or
operators are to submit data for specified
chemicals to appropriate government
agencies.
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. There
are other Title III provisions supporting
emergency planning which will be dis-
cussed in future EPA regulations and guid-
ance documents.
^ C. Resource Conservation and Recov-
ery Act
The Resource Conservation and Recovery
Act (RCRA) established a framework for
the proper management and disposal of
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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,
recycling, and new treatments for hazard-
ous 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, persdns 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. Although coordination with local
community emergency response agen-
cies is required by regulation (40 CFR
264.37), EPA strongly encourages active
community coordination of local response
capabilities with facility plans.
When a community is preparing an emer-
gency plan, it should coordinate with EPA
and the States on underground storage
tanks, which are regulated under Subtitle 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.
1.4.2 State and Local Requirements
Many States have adopted individual laws
and regulations that address local govern-
ments' involvement in hazardous materi-
als. Local authorities should investigate
State requirements and programs before
they initiate preparedness and planning
activities. Emergency plans should in-
clude consideration of any State or local
community right-to-know laws. When
these laws are more demanding than the
Federal law, the State and local laws
sometimes take precedence over the
Federal law.
1.5 Related Programs and Materials
This general planning guide for hazardous
materials incidents has been developed
cooperatively by several Federal agen-
cies. Because emergency planning is a
complex process involving a variety of is-
sues 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.
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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).
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' site-specific
guidance, criteria for identifying acutely
toxic chemicals, 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.
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, hazardous
materials inspection and enforcement,
training, and legal authority for planning.
Communities preparing an emergency
plan for transportation-related hazards
might use Community Teamwork in con-
junction 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 book is keyed to
the identification placards required by
DOT regulations to be displayed promi-
Page 8
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nently on vehicles transporting hazardous
materials. All first responders should
have copies of the Emergency Response
Guidebook and know how to use it.
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 local chemical plant manag-
ers to take the initiative in cooperating
with local communities to develop inte-
grated emergency plans for responding to
hazardous materials incidents. Because
chemical industry representatives can be
especially knowledgeable during the plan-
ning process, and because many chemi-
cal plant officials are willing and able to
share equipment and personnel during re-
sponse operations, community planners
should seek out local CMA/CAER partici-
pants. Even if no such local initiative is in
place, community planners can approach
chemical plant managers or contact CMA
and ask for assistance in the spirit of the
CAER program.
Users of this general planning guide might
also acquire 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 D.)
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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. Eniist-
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.
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
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 team leader and for team
members Introduction to Emergency
Management, and Emergency Planning.
Course materials and the schedule of of-
ferings are available through the State or
local emergency management agency.
(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 emergency planning
committees for each district. The State
commission might follow the guidance in
this chapter when appointing planning
committees.)
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:
2.2 The Planning Team
Page 10
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~ The members of the group must
have the ability, the commit-
ment, the authority, and re-
sources to get the job done;
~ 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
emergency response and re-
sponse planning;
~ The members of the group must
agree on their purpose and be
able to work cooperatively with
one another; and
~ 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.
2.2.2 Composition of the Team
When hazardous materials are present in
an area, there are many individuals with
the common goal of assuring that ade-
quate resources and plans are in place to
respond to accidental releases. These in-
dividuals include, among others:
~ People living or working near
facilities and transportation
routes where hazardous materi-
als may be present and who
could be endangered in case of
an incident;
~ Owners, managers, workers,
and labor organizations associ-
ated with the facilities and trans-
portation systems;
~ Officials of the legislative and
executive branches of govern-
ment responsible for establish-
ing, financing, and implementing
accident prevention, response,
and environmental programs;
~ Local citizens with environ-
mental and public health con-
cerns; and
~ Employees and officials of the
organizations that perform ac-
tual response work for incidents
involving hazardous materials,
such as firefighters, police, and
health personnel.
2.2.3 Respect for All Legitimate Inter-
ests
While all the individuals noted above have
a common interest in reducing the risks
posed by hazardous materials, their dif-
fering economic, political, and social per-
spectives may cailj'se them to favor differ-
ent means of promoting safety. For ex-
ample, people who live near a facility with
hazardous materials are likely to be
greatly concerned about avoiding any
threat to their lives, and are likely to be
less intensely concerned about the costs
of developing accident prevention and re-
sponse 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 ex-
penditures for unnecessarily elaborate
prevention and response measures.
Also, facility managers may be reluctant
for proprietary reasons to disclose materi-
als and processes.
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.
Page 11
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Exhibit 2
POTENTIAL GROUPS AND AGENCIES FOR 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
'Fire department (paid and volunteer)
'Police department
'Emergency management or civil defense agency (usually the lead agency)
"Environmental agency (e.g., air or water pollution controi agency)
'Health department
'Hospitals, ambulance squad, veterinarians, medical community
'Transportation agency (e.g., DOT, port authority, transit authority, bus company)
'Industry (e.g., chemical and transportation)
Coast Guard/EPA representative
Technical experts (e.g., chemist, engineer)
'Community liaison representative
'Public information representative (e.g., local radio, TV, press)
Part B: Other groups/agencies that can be included in the planning process, depend-
ing on the community's individual priorities:
Agriculture agency
Public works (e.g., waste disposal, water, sanitation, and roads)
Planning department
Other agencies (e.g., welfare, parks, and utilities)
Municipal/county legal counsel
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 and representatives of affected neighbor-
hoods
Schools
Key representatives from bordering cities and counties
State representatives (Governor, Senator's office, State agencies)
Federal agency representatives (e.g., FEMA, DOT/RSPA, ATSDR, OSHA)
('Required by Title III of SARA)
8CW08WW08 MttMOOfl WWW
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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.
2.2.4 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 ease the process of
gathering necessary data for planning. Fi-
nally, local governments generally have
the legislative authority to raise funds for
equipment and personnel required for
emergency response. Support from the
executive and legislative branches is es-
sential to successful planning. Appropri-
ate government leaders must give ade-
quate authority to those responsible for
emergency planning.
2.2.5 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 substance, and
because many facility employees have
technical expertise that will be helpful to
the planning team, the team should in-
clude one or more facility representatives.
Title III of SARA requires facility owners or
operators to notify the emergency plan-
ning committee" of a facility representative
who will participate in the emergency plan-
ning process as a facility emergency co-
ordinator. In planning districts that include
several fixed facilities, one or more repre-
sentative 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).
2.2.6 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.
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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' best 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-
see the team's efforts through the entire
planning process. Because the role of
leader is so significant, a back-up or
vice-chair could also be named.
Five factors are of major importance in
selecting a team leader:
~ The degree of respect held for
the person by groups with an in-
terest in hazardous materials;
Logical sources for a team leader include:
~ 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 loses an elec-
tion.
~ 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.
~ 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 an EOP. In some
States, existing laws require that
this agency be the lead agency
to prepare and distribute emer-
gency plans.
~ Availability of time and re-
sources;
~ The person's history of working
relationships with concerned
community agencies and organi-
zations;
~ The person's management and
communication skills; and
~ The person's existing responsi-
bilities related to emergency
planning, prevention, and re-
sponse.
Page 14
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~ 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.
~ 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.
~ 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
community's fire chief may appear to
have all the right resources for addressing
hazardous materials incidents. But if that
individual does not interact well with other
local officials, it might be best to look for a
different leader.
If a multi-hazard emergency operations
plan already exists, that plan's response
coordinator could be a good choice for
the hazardous materials emergency plan-
ning leadership position. This person is
knowledgeable in 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:
~ 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.
~ 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. This
higher level of participation can,
however, cause the process to
take longer.
~ 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
Page 15
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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.
~ B. Managing the Planning Tasks
The monitoring and approval of planning
assignments are the central responsibili-
ties of the planning tfeam. In discharging
these responsibilities, it is recommended
that the planning team operate on a con-
sensus basis, reaching general agree-
ment by all members of the team.
Achieving consensus takes more time
than majority voting, but it is the best way
to ensure that all represented parties have
an opportunity to express their views and
that the decisions represent and balance
competing interests. If it is determined
that a consensus method is inappropriate
or impossible (e.g., because of the multi-
jurisdictional nature of a group), the plan-
ning team should formally decide how is-
sues 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.
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,
Page 16
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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
E) 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.
~ 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.
~ Modeling. Planners might con-
sider developing 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.
~ 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
up the chemical (s).
~ 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). Area
maps with information about
transportation and evacuation
routes, hospital and school loca-
tions, and other emergency-re-
lated information, can also be
stored in computer disks. Com-
munities that intend to use com-
puters on scene should provide
a printer on scene also.
2.4 Beginning to Plan
When the planning team members and
their leader have been identified and a
process for managing the planning tasks
is in place, the team should address sev-
eral interrelated tasks. These planning
tasks are described in the next chapter.
Page 17
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3. Tasks of the Planning Team
The major tasks of the planning team in
completing hazardous materials planning
are:
~ 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;
~ Hazards identification and
analysis, that identifies facilities
and transportation routes with
hazardous materials and deter-
mines the associated hazards
posed lo the community;
~ Assessment of prevention and
response capabilities, that iden-
tifies existing prevention meas-
ures, response capabilities (in-
cluding mutual aid agreements),
and plans, and assesses their
adequacy;
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
~ 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
~ Development of an ongoing
emergency response exercise
program that helps test and
evaluate all the components of
the emergency response plan
annually.
This chapter discusses Ihe 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.
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:
~ State and local emergency man-
agement agencies;
3.2 Review of Existing Plans
Page 18
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~ Fire departments;
~ Police departments;
~ State and local environmental
agencies;
~ State and local transportation
agencies;
~ State and local public health
agencies;
~ Public service agencies;
~ Volunteer groups, such as the
Red Cross;
~ Local industry and industrial as-
sociations; and
~ 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 OSC and RRT covering
their area through the EPA Regional office
or USCG district office. (See Appendix E
for a list of these contacts.)
3.3 Hazards 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, vulnerabiity, risk have different technical meanings but
are sometimes used interchangeably. This guidance adopts the following definitions:
~ Hazard. Any situation that has the potential for causing damage to life, property,
and the environment.
~ Vulnerability. The susceptibility of life, property, and the environment to dam-
age if a hazard manifests its potential.
~ Risk. The probability that damage to life, property, and the environment will oc-
cur.
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 neither be possi-
ble nor desirable. This may be particularly true for smatler 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.
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As important as knowing how to perform a hazards analysis is deciding how much 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.
*="" H°FRpq°Ro°qnnnrn n nnnjurrrn
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 guidance presents a method
that may be used to- assist in ranking hazards posed by less prevalent but acutely toxic
chemicals, such as chlorine, ammonia, and hydrochloric 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 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 damage to life, property, and the environment due to a
hazardous materials spill or release. The hazards identification should indicate:
~ The types and quantities of hazardous materials located in or transported
through a community;
~ The location of hazardous materials facilities and routes; and
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~ 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:
~ Chemical plants;
~ Refineries;
~ Industrial facilities;
~ Petroleum and natural gas tank farms;
~ Storage facilities/warehouses;
~ Trucking terminals;
~ Railroad yards;
~ Hospital, educational, and governmental facilities;
~ Waste disposal and treatment facilities; qrr
~ Waterfront facilities, particularly commercial marine terminals;
~ Vessels in port;
~ Airports;
~ Nuclear facilities; and
~ Major transportation corridors and transfer points.
For individual facilities, consider hazardous materials:
~ Production;
~ Storage;
~ Processing;
~ Transportation; and
~ 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 planning committee a material
safety data sheet for specified chemicals, and emergency and hazardous chemical inven-
tory forms.) Use the CEPP guidance for help in evaluating the hazards associated with a
particular hazardous material.
The hazards identification should result in compilation of those situations that pose the
most serious damage to the community. Location maps and charts are an excellent
means of depicting this information.
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~ 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:
~ The extent of the zone of impact (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);
~ The population, in terms of size and types (e.g., residents, employees), that
could be expected to be within the zone of impact at any given time;
~ 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
~ The environment that may be affected, especially sensitive natural areas and
endangered species.
Refer to the CEPP guidance or DOT'S Emergency Response Guidebook* to obtain informa-
tion on the zone of impact for a release of hazardous materials. For information on the
population, property, and environmental resources within the zone of impact, consider
conducting:
~ A windshield survey of the area (i.e., first hand observation by driving through
an area);
~ Interviews of fire, police, and planning department personnel; and
~ A review of planning department documents, and statistics on land use, popula-
tion, highway usage, and 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 probable damage that may occur in the community due to
a hazardous materials release. The risk analysis may provide information on:
~ The type of risk to people (acute, delayed, chronic) and the associated high-
risk groups;
~ The type of risk to property (temporary, repairable, permanent);
~ The type of risk to the environment (recoverable, permanent); and
~ 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).
*Fire, police, and other emergency services personnel should have a copy of this guide.
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Use the Chemical Profiles in the CEPP guidance or a similar guide to obtain information on
the type of risk associated with a particular hazardous material.
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. 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 re-
ported to a State agency. (As indicated in Section 1.4.1, industry is required to provide
inventory and release information to the appropriate emergency planning committee.)
Such requirements provide 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 should be an opening for
continuing 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
commercial facility's needs to protect confidential business information will encourage a
facility to be forthcoming with the information necessary for the community's emergency
planning. Once the dialogue is established, 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.
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-
eludes:
~
Technical experts;
~
Facility emergency plans;
~
Cleanup and recycling capabilities;
~
Spill prevention control and countermeasures (SPCC);
~
Training and safe handling instructions; and
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~ 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 and B are identified as two among other major hazards in the commu-
nity. Information for the exhibit could have been obtained from windshield surveys of the
area; the CEPP guidance; and interviews with fire, police, county planners, and facility
representatives. These-interviews also could have provided input into the exhibit's quali-
tative assessments of hazard occurrence.
Once completed, the hazards analysis is an essential tool in the planning process. It
assists the planning team to decide;
~ The type of plan that is needed;
~ The level of detail that is necessary;
~ The types of response to emphasize; and
~ Priority hazards or areas for planning.
Before initiating plan development, however, the planning team should complete an as-
sessment of available response resources, including capabilities provided through mutual
aid agreements. Guidance for conducting such an assessment is presented in the follow-
ing section.
3.4 Capability Assessment
This section contains sample questions to help the planning team evaluate 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 representative from
industrial facilities 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.
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Exhibit 3
EXAMPLE HAZARDS ANALYSIS FOR A HYPOTHETICAL COMMUNITY
Information Requirements
Hazard A
Hazard B
1. Hazards Identification
(Major Hazards)
2. Vulnerability Analysis
a. Potential zone of impact
b. Population within zone
of impact
c. Private and public prop-
erty that may be damaged
d. Environment that may
be affected
Accidental release of chlorine from
a water treatment plant.
Small leak: 140 feet in all directions.
Large spill: 290 feet in all directions,
an area 0.7 miles wide and one mile
long in downwind direction." Fluctu-
ating wind patterns call for evacuation
within one mile in all directions of site.
Approximately 500 residents and
workers within one mile of site.
Facility equipment, vehicles, and
structures susceptible to damage
from corrosive fumes.* Community's
water supply may be affected given
that the facility is its primary supplier.
Aquatic life is the primary natural
resource that might be affected.
Collision and rupture of a tank truck
transporting ammonia at interchange
of two interstate highways.
Small leak: 80 feet in all directions.
Large spill: 160 feet in all directions;
an area 0.4 miles wide and 0.6 miles
long in a downwind direction." Fluctu-
ating wind patterns call for evacuation
within 0.6 miles in all directions of
interchange.
Up to 700 persons in residences,
commercial establishments, or vehicles
within 0.6 mile of interchange.
Highway and nearby vehicles susceptible
to damage from fire or explosions. No
other substantial structure within 1500
feet. Within 0.6 mile there are 50
residences, four fast food restaurants,
one 30-room motel, a truck stop, two
gas stations, and a mini-market.
Adjacent forest preserve is highly
susceptible to fires.
-------
Exhibit 3 (Continued)
EXAMPLE HAZARDS ANALYSIS FOR A HYPOTHETICAL COMMUNITY
Information Requirements
Hazard A
Hazard B
3. Risk Analysis
a. Risk to people
Chlorine is poisonous; may be fatal
if inhaled. Respiratory conditions
aggravated by exposure. Contact
may cause burns to skin and eyes.
Effects may be delayed."
Vapors cause irritation of eyes and
respiratory tract. Liquid will burn
skin and eyes. Poisonous; may be
fatal rf inhaled. Contact may cause
burns to skin and eyes. Contact with
liquid may cause frostbite. Effects
may be delayed.*
b. Risk to property
c. Risk to environment
d. Probability of hazard
occurrence
e. Probability of simul-
taneous emergencies
f. Unusual environmental
conditions
Possible superficial damage to faci-
lity equipment, vehicles, and structures
from corrosive fumes (repairable).
Possible destruction of down-river
aquatic life
-------
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?
~ Is there a list of potentially toxic chemicals available? What are their physical
and chemical characteristics, potential for causing adverse health effects, con-
trols, interactions with other chemicals?
~ Has a hazard risk analysis been prepared for the facility? If so, has it been
updated?
~ Have operation or storage procedures been modified to reduce the probability of
a release?
~ Is on-site emergency response equipment available (e.g., fire fighting equip-
ment, personal protective equipment, communications equipment) and trained
personnel to provide on-site initial response efforts?
~ 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.)
~ Is there an emergency medical care system on site?
~ Are the local hospitals prepared to accept and provide care to patients who have
been exposed to chemicals?
~ 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?
~ Are employee evacuation plans in effect and are the employees trained to use
them in the event of an emergency?
~ What kind 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?
~ What is the mechanism to alert employees and the surrounding community in
the event of a release at the facility?
~ Is there a standard operating procedure for the personal protection of commu-
nity members at the time of an emergency?
~ Does the community know about the meaning of various alarms or warning sys-
tems? Are tests conducted?
~ How do facility personnel coordinate with the community government and local
emergency and medical services during emergencies?
~ What mutual aid agreements are in place for obtaining emergency response
assistance from other industry members? With whom?
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~ Are there any contacts or other pre-arrangements in place with cleanup special-
ists for cleanup and removal of releases, or is this handled in-house? How
much time is required for the cleanup specialists to respond?
~ 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?)
~ Are wind direction indicators positioned within the facility perimeter to determine
in what direction a released chemical will travel? Where are they located?
~ Is there capability for modeling vapor cloud dispersion?
~ Are auxiliary power systems available to perform emergency system functions in
case of power outages at the facility?
~ How often is the safety plan tested and updated? When was it last tested and
updated?
~ Does the company participate in CHEMNET or the CAER program?
~ Does the company have the capability for responding to off-site emergencies?
Is this limited to the company's products?
What is the safety training plan for employees?
~ 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?
~ Are simulated emergencies conducted for training1-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?
~ Are employees given training in methods for coordinating with local community
emergency response and medical services during emergencies? How often?
Is there an emergency response equipment and systems inspection plan?
~ Is there a method for identifying emergency response equipment problems?
Describe it.
~ Is there testing of on-site alarms, warning signals, and emergency response
equipment? How often is this equipment tested and replaced?
3.4.2 Transporter Resources
What cargo information and response organization do ship, train, and truck operations
provide at a release?
~ Do transport shipping papers identify hazardous materials, their physical and
chemical characteristics, control techniques, and interactions with other chemi-
cals?
~ Do transports have proper placards?
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~ Are there standard operating procedures (SOPs) established for release situ-
ations? Have these procedures been updated to reflect current cargo charac-
teristics?
~ 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?
~ What emergency response equipment is carried by each transporter (e.g., pro-
tective clothing, breathing apparatus, chemical extinguishers)?
~ Do transports have first-aid equipment (e.g., dressings for chemical burns, and
water to rinse off toxic chemicals)?
~ By what means do operators communicate with emergency response authori-
ties?
~ Do transport operations have their own emergency response units?
~ What arrangements have been established with cleanup specialists for removal
of a release?
What is the safety training plan for operators?
~ Are operators trained in release SOPs and to use emergency response equip-
ment? How often is training updated?
~ How often are release drills conducted? Who evaluates these drills and do the
evaluations become a part of an employee's file?
~ 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?
~ What inspections are conducted? What leak detection and equipment readiness
tests are done? What is the schedule for inspections and tests?
~ Are problems identified in inspections corrected? How are maintenance sched-
ules established?
3.4.3. Community Resources
What local agencies make up the community's existing response preparedness network?
Some examples include:
~ Fire department;
~ Police/sheriff/highway patrol;
~ Emergency medical/paramedic service associated with local hospitals or fire
and police departments;
~ Emergency management or civil defense agency;
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~ Public health agency;
~ Environmental agency;
~ Public works and/or transportation departments;
~ Red Cross; and
~ 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?
~ 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?
~ Has the community performed any assessments of existing prevention and re-
sponse capabilities within its own emergency response network?
~ Does the community maintain an up-to-date technical reference library of re-
sponse procedures for hazardous materials?
~ 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?
~ 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-
gency operating center), the name of the contact, position, 24-hour telephone
number, and the chain of command.
~ 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 on the local level to respond to
emergencies? How can the equipment, materials, and personnel be made available to
trained users at the scene of an incident?
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Does the community have specialized emergency response teams to respond to hazard-
ous materials releases?
~ Have the local emergency services (fire, police, medical) had any hazardous
materials training, and if so, do they have and use any specialized equipment?
~ Are local hospitals able to decontaminate and treat numerous exposure victims
quickly and effectively?
~ 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?
~ Has the community sought any resources from industry to help respond to
emergencies?
Is the community emergency transportation network defined?
~ Does the community have specific evacuation routes designated? What are
these evacuation routes? Is the general public aware of these routes?
~ 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)?
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?
~ What does the communications network involve (e.g., special radio frequency,
network channel, siren, dedicated phone lines, computer hook-up)?
~ Is there an up-to-date list, with telephone numbers, of radio and television sta-
tions (including cable companies) that broadcast in the area?
~ 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/HACS, 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?
~ Does the list of resources include: wreck clearing, transport, cleanup, disposal,
health, analytical sampling laboratories, and detoxifying agents?
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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 prevention
and response capabilities, it can take
steps to make serious incidents less
likely. 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 live
safely with hazardous materials. The
team should also begin to write an emer-
gency plan. Chapter 4 describes two ap-
proaches to developing or revising an
emergency plan. Chapter 5 describes
elements related to hazardous materials
incidents that should be included in which-
ever type of plan the community 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, those communities
receiving FEMA funds are required to in-
corporate hazardous materials planning
into their multi-hazard emergency opera-
tions plan (EOP). Other communities are
encouraged to prepare a multi-hazard
EOP in accord with CPG 1 -8 since it is the
most comprehensive approach to emer-
gency planning. Not every community,
however, may be ready for or capable of
such a comprehensive approach. Be-
cause each community must plan in light
of its own situation and resources, a less
exhaustive approach may be the only
practical, realistic 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 to a multi-hazard EOP following
the approach described in FEMA's CPG
1-8, and (2) development or revision of a
single-hazard hazardous materials plan.
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. Dealing with the gen-
eral aspects of all hazards first and then
looking at each potential hazard individu-
ally to see if any unique aspects are in-
volved results in efficiencies and econo-
mies in the long run. Multi-hazard EOPs
also help ensure that plans and systems
are reasonably compatible if a large-scale
hazardous materials incident requires a si-
multaneous, coordinated response by
more than one community or more than
one level of government.
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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.
Other communities not receiving FEMA
funds are encouraged to use the multi-
hazard approach to emergency planning
because it is economical to prepare one
comprehensive multi-hazard plan as op-
posed to developing separate structures,
resources, and plans to deal with each
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
type of hazard. Communities that want to
develop Standard Operating Procedures
(SOP) manuals could begin with informa-
tion included in the functional annexes of a
multi-hazard EOP.
CPG 1-8 provides flexible guidance, rec-
ognizing that substantial variation in plan-
ning may exist from community to com-
munity. 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 communities
of all sizes in all parts of the country.
Planners should, therefore, use good
judgment and common sense in applying
CPG 1-8 principles to meet their needs.
The community has latitude in formatting
the plan but should closely follow the ba-
sic 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.
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.
best suited to its own circumstances,
taking advantage of the sample outline
where appropriate.
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
4.3 Single-Hazard Emergency Plan
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Exhibit 4
SAMPLE OUTLINE OF A HAZARDOUS MATERIALS EMERGENCY PLAN
(NOTE: Depending upon local circumstances, communities will develop some sections
more extensively than other sections.)
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
3. 'Communications (among Responders)
4. Warning Systems and Emergency Public Notification
5. Public Information/Community Relations
6. Resource Management
7. Health and Medical
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
These "Response Functions" are equivalent to the "functional annexes" of a multi-haz-
ard emergency operations plan described in CPG 1-8.
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Exhibit 4 (Continued)
SAMPLE OUTLINE OF A HAZARDOUS MATERIALS EMERGENCY PLAN
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
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.
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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 or plan need to evaluate their pre-
sent appendix or 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 release of hazardous materials.
Title III of SARA requires each emer-
gency plan to include at least each of the
following:
(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.
(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.
(3) Designation of a community emer-
gency coordinator and facility emer-
gency coordinators, who shall make
determinations necessary to imple-
ment the plan.
(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.
(5) Methods for determining the occur-
rence of a release, and the area or
population likely to be affected by
such release.
(6) A description of emergency equip-
ment and facilities in the community
and at each facility in the commu-
nity subject to Title III require-
ments, and an identification of the
persons responsible for such equip-
ment and facilities.
(7) Evacuation plans, including provi-
sions for a precautionary evacu-
ation and alternative traffic routes.
(8) Training programs, including sched-
ules for training of local emergency
response and medical personnel.
(9) Methods and schedules for exercis-
ing the emergency plan.
These requirements are mentioned in ap-
propriate sections of this chapter.
The various planning elements are dis-
cussed here in the same order as they ap-
pear in the sample outline for a single-
hazard plan in Chapter 4. Community
planners might choose, however, to order
these planning elements differently in a
multi-hazard plan following the model of
CPG 1-8.
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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.
Planning Element A: Introduction
Planning Element A.1: Incident Information Summary
~ 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 4digit identification numbers
o Placard/label information
Characteristics of material (e.g., color, smell, physical effects), only if readily
detectable
Present status of the material (e.g., gas, liquid)
Total amount of material that may be released
Other hazardous materials in area
Amount of material released so far/duration of release
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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 can be 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 determine the precise identity of
the hazardous materials involved in transportation incidents, and to take initial
precautionary and containment steps. First responders can use this informa-
tion to consult DOT'S Emergency Response Guidebook. Additional information
about the identity and characteristics of chemicals is available by calling
CHEMTREC (800-424-9300).
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.
Planning Element A.2: Promulgation Document
~ 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.
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Planning Element A.3: Legal Authority and Responsibility
for Responding
~ Authorizing legislation and regulations
Federal (e.g., CERCLA, Clean Water Act, National Contingency Plan, and Disas-
ter Relief Act)
State
Regional
Local
~ Mandated agency responsibilities
~ Letters of agreement
Comment: If there are applicable laws besides CERCLA regarding planning for response
to hazardous materials releases, list them 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 gath-
ered here for easy reference.
Planning Element A.6: Assumptions/Planning Factors
~ Geography
Sensitive environmental areas
Water supplies
Population density
Particularly sensitive institutions (e.g., schools, hospitals, homes for the aged)
~ Climate
~ Particular characteristics of each facility and the transportation routes for which the
plan is intended
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On-site details
Neighboring population
Surrounding terrain
Known impediments (tunnels, bridges)
Other areas at risk
~ 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. Assumptions are the advance judgments
concerning what would happen in the case of an accidental spill or release.
For example, planners might assume that a certain percentage of local resi-
dents on their own will evacuate the area along routes other than specified
evacuation routes.
copotoooofwwowpowoooomoiiwwwooooboooooowoowb
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.
Planning Element A.7b: Organizational Roles and Responsibilities
~ Municipal government
Chief elected official
Emergency management director
Communications personnel
Fire service
Law enforcement
Public health agency
Environmental agency
Public works
~ County government
~ Officials of fixed facilities and/or transportation companies
~ Nearby municipal and county governments
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~ State government
Environmental protection agency
Emergency management agency
Public health agency
Transportation organization
Public safety organization
~ Federal government
EPA
FEMA
DOT
ATSDR
USCG
OSHA
DOD
DOE
RRT
~ Predetermined arrangements
~ 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 pre-response (planning), response (imple-
menting the plan during an incident), and post-response (cleanup and resto-
ration) activities to a hazardous materials incident. One organization should
be given command and control responsibility for these three phases of the
emergency response. The role of each organization/official should be clearly
described. (Note: The above list is not meant to be complete. Each com-
munity 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.
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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.
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 and medical personnel to re-
spond to any releases of such substances. The NCP, the Federal Regional
contingency plan, any Federal local contingency ^lan for the area, and any
State plan should be referenced. Of special impprtance are all local emer-
gency 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
~ List of organizations/persons receiving plan
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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.
Planning Element A.9: Record of Amendments
~ 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
~ 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 public
safety people and others. Examples of organizations for possible inclusion in
a telephone roster are as follows:
Page 44
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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
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
Volunteer Groups
Red Cross
Salvation Army
Church Groups
Ham Radio Operators
Off-Road Vehicle Clubs
State Assistance
State Environmental Agency
Emergency Management Agency
Department of Transportation
Police
Public Health Department
Department of Agriculture
Federal Assistance
Federal On-Scene Coordinator
U.S. Dept. of Transportation
U.S. Coast Guard
U.S. Environmental Protection Agency
Federal Emergency Management Agency 24 hours 202-646-2400
U.S. Department of Agriculture
Media
Television
Newspaper
Radio
Page 45
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Occupational Safety and Health Administration
Agency for Toxic Substances and Disease Registry
24 hours
National Response Center
U.S. Army, Navy, Air Force
Nuclear Regulatory Commission
Radioactive Material
Emergency Response
U.S. Department of Energy
Bomb Disposal and/or Explosive
Ordnance Team, U.S. Army
Other Emeroencv Assistance
CHEMTREC
CHEMNET
CHLOREP
NACA Pesticide Safety Team
American Association of Railroads/
Bureau of Explosives
Poison Control Center
Cleanup Contractor
24 hours
in Washington, DC area
or
24 hours
24 hours
24 hours
24 hours
24 hours
404-452-4100
800-424-8802
202-426-2675
202-267-2675
800-424-9300
800-424-9300
800-424-9300
800-424-9300
202-835-9300
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.
Function 1: Initial Notification of Response Agencies
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)
Page 46
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~ 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 under the reportable quan-
tity (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, hospitals, nursing homes, day care centers,
industries, detention centers), according to the severity of the incident.
Function 2: Direction and Control
~ Name of on-scene authority
~ Chain of command (illustrated in a block diagram)
~ Criteria for activating emergency operating center
~ Method for establishing on-scene command post and communications network for
response team(s)
~ Method for activating emergency response teams
~ List of priorities for response actions
~ 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 will prove helpful to identify (by title or
Page 47
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position) the one individual responsible for each participating organization,
and the one individual responsible for each major function and service.
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
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.
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).
Page 48
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Response Level
Description
I. Potential
Emergency
Condition
Limited
Emergency
Condition
An incident 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.
Full An incident involving a severe
Emergency hazard or a large area which
Condition 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.
Response Activities
Fire Department
Emergency Medical
Services
Police Department
Partial EOC Staff
Public Information
CHEMTREC
National Response
Center
All Agencies in
Level I
HAZMAT Teams
EOC Staff
Public Works
Department
Health Department
Red Cross
County Department of
Emergency Management
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)
~ How various responders keep each other informed
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. As a minimum, it may be beneficial to establish radio networks that
will allow for communication among those performing similar functions. In
order to avoid possible explosion/fire hazards, all communications equipment
(including walkie-talkies) should be intrinsically safe.
WOOW»WOWWOOO(WWWWOWWWMWWOOOOOWWOO»»WmiWW)OOWOW>OOOtWWgWQWIlflllllllWIWW»OWWOgowil|WWWWO>gO(CWWOWOWWWOWWW
-------
addition to sirens arid the Emergency Broadcast System, it may be neces-
sary 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
~ Method to educate the public for possible emergencies
~ 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: A public information program to explain safety procedures during an incident
is important. This program could include pamphlets; newspaper stories; pe-
riodic radio and television announcements; and programs for schools, hospi-
tals, 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. 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
~ List of personnel needed for emergency response
~ Training requirements for hazardous materials response personnel
~ List of vehicles needed for emergency response
~ List of equipment (both heavy equipment and personal protective equipment)
needed for emergency response
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-
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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/ADL "Guidelines for the Selection of Chemical Protec-
tive Clothing" distributed by the American Conference of Governmental In-
dustrial Hygienists.
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
~ Provisions for ambulance service
~ Provisions for medical treatment
^Comment: This section should indicate how medical personnel and ambulance service
can be summoned. It may be appropriate to establish mutual aid agree-
ments with nearby communities to provide backup emergency medical per-
sonnel and equipment. The community should determine a policy (e.g.,
triage) for establishing priorities for the use of medical resources during an
emergency. Emergency medical teams and hospital personnel must be
trained in proper methods for decontaminating and treating persons exposed
to hazardous chemicals. Planners should include mental health specialists as
part of the team assisting victims of serious incidents.
Function 8: Response Personnel Safety
~ Standard operating procedure for entering and leaving sites
~ Accountability for personnel entering and leaving the sites
~ Decontamination procedures
~ Recommended safety and health equipment
~ Personal safety precautions
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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) H 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.
Function 9: Personal Protection of Citizens
Function 9a: Indoor Protection
~ 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. Frequently a plume will move quickly past homes. Modern housing
has adequate air circulation to allow residents to remain safely inside for an
extended period of time. Since central and window air conditioners can eas-
ily circulate airborne toxic substances, a warning should be given to shut off
heating and air conditioning systems both in private and Institutional settings.
In order for an indoor protective strategy to be effective, planning and pre-
paredness activities should provide:
An emergency management system and decision-milking criteria for de-
termining 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.
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Function 9b: Evacuation Procedures
~ Title of person and alternate (s) who can order/recommend an evacuation
~ Risk zones where evacuation could be necessary and a method for notifying these
places
~ Provisions for a precautionary evacuation
~ Methods for controlling traffic flow and providing alternate traffic routes
~ Shelter locations and other provisions for evacuations (e.g., special assistance for
hospitals)
~ Agreements with nearby jurisdictions to receive evacuees
~ Agreements with hospitals outside the local juridictions
~ Protective shelter for relocated populations
~ Reception and care of evacuees
~ 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
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).
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Function 9c: Other Public Protection Strategies
~ Relocation
~ Water supply protection
~ 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 to a treatment plant. It may be necessary to divert
sewage, creating another public health threat and environmental problems.
Function 10: Fire and Rescue
~ Chain of command among firefighters
~ List of available support systems
~ 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.)
This section should also identify any mutual aid or Good Samaritan agree-
ments with neighboring fire departments, hazmat teams, and other support
systems.
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Function 11: Law Enforcement
~ Chain of command for law enforcement officials
~ 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
~ Field monitoring teams
~ Provision for environmental assessment, biological monitoring, and contamination
surveys
~ 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
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.
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Function 13: Human Services
~ List of agencies providing human services
~ 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.
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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
~ Cleanup/disposal contractors and services provided;
~ Cleanup material and equipment;
~ Communications equipment;
~ Emergency transportation (e.g., aircraft, four-wheel-drive vehicles, boats);
~ Cleanup personnel;
~ Personal protective equipment; and
~ 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:
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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 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 the governors or appropriate
State agency offices for information on State requirements for hazardous
waste disposal.
Planning Element E: Documentation and Investigative Follow-Up
~ List of required reports
~ Reasons for requiring the reports
~ Format for reports
~ Methods for determining whether the response mechanism worked properly
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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
~ 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 frequency of exercises; and
(3) A procedure for evaluating performance and making changes to plans
as necessary. (See Chapter 6 of this guide.)
Planning Element F.2: Updating the Plan
~ Title and organization of responsible person (s)
~ Change notification procedures
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~ 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 begin to be made, used, stored, or
transported 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)
~ Identification of hazards
~ Analysis of vulnerability
~ 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
conditions might exist during a spill or release. To prepare a hazards analy-
sis, consult Chapter 3 of this guide, EPA's CEPP guidance, and DOT's Com-
munity Teamwork and Lessons Learned. Ask Federal offices (listed in Appen-
dix E) for information about available computer programs to assist in a haz-
ards analysis.
Individual data sheets and maps for each facility and transportation route of
interest could be included in this section. Similar data could be included for
recurrent shipments of hazardous materials through the area. In communi-
ties 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.
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Planning Element H: References
Planning Element H.1: Laboratory, Consultant,
and Other Technical Support Resources
~ 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.
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Planning Element H.2: Technical Library
~ 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
Comment: Industry sources can provide many specific publications dealing with hazard-
ous materials. This section of the plan will list those published resources that
efa 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.
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 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, hazardous materials pre-
sent, Federal and State laws, local laws
and ordinances, road configurations,
population change, emergency telephone
numbers, and facility location. This chap-
ter describes key aspects of appraisal and
provides specific guidance for maintaining
an updated hazardous materials emer-
gency 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 C is an adaptation of criteria devel-
oped by the National Response Team that
includes 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 haz-
ardous materials appendices to a multi-
hazard EOP, the team will have to review
the basic EOP as well as the functional an-
nexes to obtain an overall assessment of
content. Once the team accomplishes
this internal review the plan should be re-
vised in preparation for external 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.
^ 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:
~ The safety or environmental en-
gineer in a local industry;
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~ Responsible authorities from
other political jurisdictions (e.g.,
fire chief, police, environmental
and/or health officers);
~ A local college professor familiar
with hazardous materials re-
sponse operations; and
~ 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 presents a comprehensive list of
potential peer reviewers. Those selected
as peer reviewers should use the criteria
contained in Appendix C to develop their
assessments of the plan.
^ B. 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:
~ Community workshops with
short presentations by planning
team members followed by a
question-and answer period;
~ Publication of notice "for com-
ment" in local newspapers, of-
fering interested individuals and
groups an opportunity to express
their views in writing;
~ Public meetings at which citi-
zens can submit oral and written
comments;
~ 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
~ 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
accord with Title III of SARA are to submit
a copy of the emergency plan to the State
emergency response commission for re-
view to ensure coordination of the plan
with emergency plans of other planning
districts. Federal Regional Response
Teams may review and comment upon an
emergency plan, at the request of an
emergency planning committee. FEMA
Regional offices review FEMA-funded
multi-hazard EOPs using criteria in CPG
1-8A in addition to criteria described in
Appendix C of this guide.
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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 Ihe results of
appraisal exercises should be incorpo-
rated into the plan. The following tech-
niques will aid in keeping abreast of rele-
vant changes:
~ Establish a regular review pe-
riod, preferably every six
months, but at least annually.
(Title III of SARA requires an an-
nual review.}
~ Make one reliable organization
responsible for coordination of
the review and overall
stewardship of the plan. Use of
the planning team in this role I3
recommended, but may not be
a viable option due to time avail-
ability constraints of team mem-
bers.
~ 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.
~ 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.
~ Make any sections of the plan
that are subject to frequent
changes either easily replace-
able (e.g., iooselesf, 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 responsWa lar review
should do the following:
~ 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 Ihe distribution list and
asking for any additions or cor-
rections.
~ Check all telephone numbers,
persons named with particular
responsibilities, and equipment
locations and availability. In ad-
dition, ask departments and
agencies to review sections of
the plan defining their responsi-
bilities and actions.
~ 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, location,
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.
~ If possible, the use of electronic
word processing is recom-
mended because it facilitates
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changing the plan. After a sig-
nificant number of individual
changes, the entire plan should
be redistributed to ensure com-
pleteness.
~ If practical, request an ack-
nowledgement of changes from
those who have received
changes. The best way to do
this is to include a self-
addressed postr^rd to be re-
turned with acknowledgement
(e.g., "I have received and en-
tered changes dated Signed
")
~ Attend any plan critique meet-
ings and issue changes as may
be required.
~ Integrate changes with other re-
lated plans.
6.4 Continuing Planning
While the periodic updates described
above are the primary factors in plan im-
provement, additional steps are neces-
sary to ensure current and effective plan-
ning. These include exercises, incident
reviews, and training.
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. Experi-
ence gained from real emergencies
should be used to update the plan.
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
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.
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-
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book is also helpful. CM A 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:
~ Assign responsibility for incident
review to the same organization
that is responsible for plan up-
date, for example, the planning
team.
~ 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.
~ Use questionnaires, telephone
interviews, or personal inter-
views to obtain comments and
suggestions from emergency re-
spondents. Follow-up on non-
respondents.
~ Identify plan deficiencies: items
that were overlooked, improp-
erly identified, or were not effec-
tive.
~ Convene the planning team to
review comments and make ap-
propriate plan changes.
~ Revise the plan as necessary.
Communicate personal or de-
partmental deficiencies infor-
mally to the appropriate person
or department.
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,
and the USCG offer hazardous materials
training. (In some cases, there are limits
on attendance in these courses.) Com-
munities seeking training assistance
should consult appropriate State agen-
cies. States may consult with the RRT and
the various Federal Regional and district
offices. (See Appendix E.)
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 for 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.
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Training aids can be obtained by writing
to:
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.
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APPENDIX A
LIST OF ACRONYMS
AAR/BOE American Association of 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
CDC Centers for Disease Control (HHS)
CEPP Chemical Emergency Preparedness Program
CERCLA Comprehensive Environmental Response, Compensation, and Liabil-
ity Act
CFR Code of Federal Regulations
CHEMNET A mutal 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 Review of State and Local Emergency Operations Plans
CWA Clean Water Act
DOC Department of Commerce
DOD Department of Defense
DOE Department of Energy
DOI Department of the Interior
DOJ Department of Justice
DOL Department of Labor
DOS Department of State
DOT Department of Transportation
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APPENDIX A (Continued)
LIST OF ACRONYMS
EMA
Emergency Management Agency
EMI
Emergency Management Institute
EOC
Emergency Operating Center.
EOP
Emergency Operations Plan
EPA
Environmental Protection Agency
FEMA
Federal Emergency Management Agency
FWPCA
Federal Water Pollution Control Act
HAZMAT
Hazardous Materials
HHS
Health and Human Services
IEMS
Integrated Emergency Management System
NACA
National Agricultural Chemicals Association
NCP
National Contingency Plan
NETC
National Emergency Training Center
NFA
National Fire Academy
NFPA
National Fire Protection Association
NIOSH
National Institute of Occupational Safety and Health
NOAA
National Oceanic and Atmospheric Administration
NRC
Nuclear Regulatory Commission; National Response Center
NRT
National Response Team
NUREG 0654/
Criteria for Preparation and Evaluation of Radiological Emergency
FEMA-REP-1
Response Plans and Preparedness in Support of Nuclear Power Plants
OHMTADS
Oil and Hazardous Materials Technical Assistance Data System
OSC
On-Scene Coordinator
OSHA
Occupational Safety and Health Administration (DOL)
PSTN
Pesticide Safety Team Network
RCRA
Resource Conservation and Recovery Act
REP-5
Guidance for Developing State and Local Radiological Emergency
Response Plans and Preparedness for Transportation Accidents
RQs
Reportable Quantities
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APPENDIX A (Continued)
LIST OF ACRONYMS
RRT Regional Response Team
RSPA Research and Special Programs Administration (DOT)
SARA Superfund Amendments and Reauthorization Act of 1986
SCBA Self-Contained Breathing Apparatus
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
USHHS U.S. Department of Health and Human Services
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APPENDIX B
GLOSSARY
CAER 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.
CEPP Chemical Emergency Preparedness Program developed by EPA
to address accidental releases of acutely toxic chemicals.
CERCLA 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.
CHEMNET 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
authorize 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 incident from the CHEMTREC communicator.
CHEMTREC 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 infor-
mation, including on-scene assistance when feasible. Can be
reached 24 hours a day by calling 800-424-9300.
CHLOREP 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.
CHRIS/HACS Chemical Hazards Response Information System/Hazard Assess-
ment Computer System developed by the U.S. Coast Guard.
HACS 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.
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APPENDIX B (Continued)
GLOSSARY
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
sequence for identifying hazards, assessing capabilities, setting
priorities, and scheduling activities to improve capability over
time.
EMI The Emergency Management Institute is a component of FEMA's
National Emergency Training Center located in Emmitsburg,
Maryland. 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
volunteer organizations on subjects that range from civil nuclear
preparedness systems to domestic emergencies caused by
natural 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 emergency management training requirements in communi-
ties throughout the nation.
ERT Environmental Response Team, a group of highly specialized ex-
perts available through EPA 24 hours a day.
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.
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APPENDIX B (Continued)
GLOSSARY
EOP 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.
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 techni-
cal, management, and prevention subject areas. A growing off-
campus course delivery system is operated in conjunction with
State fire training program offices.
NRC National Response Center, a communications center for activities
related to response actions, is located at Coast Quard 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
pollution 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, DOL, NRC, and DOE), is
the principal organization for implementing the NCP. When the
NRT is not activated for a response action, it serves as a stand-
ing committee to develop and maintain preparedness, to evalu-
ate methods of responding to discharges or releases, to recom-
mend needed changes in the response organization, and to rec-
ommend revisions to the NCP. The NRT may consider and
make recommendations to appropriate agencies on the training,
equipping, and protection of response teams; and necessary
research development, demonstration, and evaluation to improve
response capabilities.
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APPENDIX B (Continued)
GLOSSARY
NSF National Strike Force, made up of three Strike Teams.
The USCG counterpart to the EPA ERTs.
NUREQ 0654/ Criteria for Preparation and Evaluation of Radiological Emergency
FEMA-REP-1 Response Plans and Preparedness in Support of Nuclear Power
Plants, prepared by NRC 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 Oil and Hazardous Materials Technical Assistance Data System, a
computerized data base containing chemical, biological, and
toxicological information about more than 1,100 hazardous sub-
stances. OSCs use OHMTADS to identify unknown chemicals
and to learn how to best handle known chemicals.
OSC 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 fa-
cilities. When the NRC receives notification of a pollution inci-
dent, the NRC Duty Officer notifies the appropriate OSC, de-
pending on the location of an incident. Based on this initial re-
port and any other information that can be obtained, the OSC
makes a preliminary assessment of the need for a Federal re-
sponse. 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 un-
known or not taking appropriate action, and the response is be-
yond the capability of State and local governments, the OSC
may initiate Federal actions, using funding from the FWPCA Pol-
lution Fund for oil discharges and the CERCLA Trust Fund (Su-
perfund) for hazardous substance releases.
PSTN 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 B (Continued)
GLOSSARY
RCRA 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
standards, which are generally implemented through permits is-
sued by EPA or authorized States.
REP-5 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 ma-
terials.
RRT 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.
Superfund The trust fund established under CERCLA to provide money the
OSC can use during a cleanup.
Title III 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.
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APPENDIX C
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
prepardness 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 material release, for identifying potential
sources of a hazardous material 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 probable risk of a hazardous material release or spill.
The following criteria may assist in assessing a hazards analysis:
~ Has a hazards analysis been completed for the area? If one exists, when was it
last updated?
~ 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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~ Was it done in accord with community right-to-know laws and prefire plans?
~ Does it include the routes by which the hazardous materials are transported?
~ Have areas of public health concern been identified?
~ Have sensitive environmental areas been identified?
~ Have historical data on spill incidents been collected and evaluated?
~ Have the levels of vulnerabiity and probable locations of hazardous materials
incidents been identified?
~ 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:
~ Do clear legal authorities exist to establish a comprehensive hazardous materials
response mechanism (Federal, State, county, and local laws, ordinances, and
policies)?
~ 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?
~ Do they specify what agency(ies) has (have) overall responsibility for directing
or coordinating a hazardous materials response?
~ 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?
~ Have the agency (ies) with authority to order evacuation of the community been
identified?
~ 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
locality to locality and that emergency planning for the State and local level may involve
Page C-2
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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.
~ 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 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
~ Have each organization's authorities, responsibilities and capabilities been de-
termined for pre-response (planning), response (implementing the plan during
an incident), and post-response (cleanup and restoration) activities?
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~ Has one organization been given the command and control responsibility for
these three phases of emergency response?
~ Has a "chain of command" been established for response control through all
levels of operation?
~ 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)?
~ 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)?
~ 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?
~ Does the organizational structure provide a mechanism to meet regularly for
planning and coordination?
~ Does the organizational structure provide a mechanism to regularly exercise the
response organization?
~ Has a simulation exercise been conducted within the last year to test the organ-
izational structure?
~ Does the organizational structure provide a mechanism to review the activities
conducted during a response or exercise to correct shortfalls?
~ Have any limitations within the organizational structure been identified?
~ Is the organizational structure compatible with the Federal response organization
in the NCP?
~ Have trained and equipped incident commanders been identified?
~ Has the authority for site decisions been vested in the incident commanders?
~ Have the funding sources for a response been identified?
~ 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:
~ Have procedures been established for coordination of information during a re-
sponse?
~ Has one organization been designated to coordinate communications activities?
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~ Have common radio frequencies been established to facilitate coordination be-
tween different organizations?
Information Exchange:
~ Does a formal system exist for information sharing among agencies, organiza-
tions, and the private sector?
~ Has a system been established to ensure that "lessons learned" are passed to
the applicable organizations?
Information Dissemination:
~ Has a system been identified to carry out public information/community relations
activities?
~ Has one organization or individual been designated to coordinate with or speak
to the media concerning the release?
~ Is there a communication link with an Emergency Broadcast System (EBS) sta-
tion?
~ Does a communications system/method exist to disseminate information to re-
sponded, affected public, etc.?
~ Is this system available 24-hours per day?
~ Have alternate systems/methods of communications been identified for use if
the primary method fails?
~ Does a mechanism exist to keep telephone rosters up-to-date?
~ Are communications networks tested on a regular basis?
Information Sources and Database Sharing:
~ Is a system available to provide responders with rapid information on the haz-
ards of chemicals involved in an incident?
~ Is this information available on a 24-hour basis? Is it available in computer soft-
ware?
~ Is a system in place to update the available information sources?
Notification Procedures:
~ Have specific procedures for notification of a hazardous materials incident been
developed?
~ Are multiple notifications required by overlapping requirements (e.g., State,
county, local each have specific notification requirements)?
~ Does the initial notification system have a standardized list of information that is
collected for each incident?
~ Does a network exist for notifying and activating necessary response personnel?
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~ 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.?
~ Has a central location or phone number been established for initial notification of
an incident?
~ Is the central location or phone number accessible on a 24-hour basis?
~ Does the central location phone system have the ability to expand to a multiple
line system during an emergency?
Clearinghouse Functions:
~ 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:
~ Have the numbers of trained personnel available for hazardous materials been
determined?
~ 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?
~ Are sufficient personnel available to maintain a given level of response capability
identified as being required for the area?
~ ' Has the availability of special technical expertise (chemists, industrial hygienists,
toxicologists, occupational health physicians, etc.) necessary for response been
identified?
~ Have limitations on the use of above personnel resources been identified?
~ Do mutual aid agreements exist to facilitate interagency support between organi-
zations? f
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Training:
~ Have the training needs for the State/local area been identified?
~ Are centralized response training facilities available?
~ 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?
~ Does the organizational structure provide training and cross training for or be-
tween organizations in the response mechanism?
~ Does an organized training program for all involved response personnel exist?
Has one agency been designated to coordinate this training?
~ Have training standards or criteria been established for a given level of response
capability? Is any certification provided upon completion of the training?
~ Has the level of training available been matched to the responsibilities or capa-
bilities of the personnel being trained?
~ Does a system exist for evaluating the effectiveness of training?
~ 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?
~ Have resources and organizations available to provide training been identified?
~ Have standardized curricula been established to facilitate consistent Statewide
training?
Equipment:
~ Have response equipment requirements been identified for a given level of re-
sponse capability?
~ 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)
~ Are sufficient quantities of each type of equipment available on a sustained ba-
sis?
~ Is all available equipment capable of operating in the local environmental condi-
tions?
~ Are up-to-date equipment lists maintained? Are they computerized?
~ Are equipment lists available to all responders?
~ Are these lists broken down into the various types of equipment (e.g., protec-
tive clothing, monitoring instruments, medical supplies, transportation equip-
ment)?
~ Is there a mechanism to ensure that the lists are kept up-to-date?
~ Have procedures necessary to obtain equipment on a 24-hour basis been identi-
fied?
~ Does a program exist to carry out required maintenance of equipment?
~ Are there maintenance and repair records for each piece of equipment?
~ Have mutual aid agreements been established for the use of specialized re-
sponse equipment?
~ Is sufficient communications equipment available for notifying personnel or to
transmit information? Is the equipment of various participating agencies com-
patible?
~ Is transportation equipment available for moving equipment rapidly to the scene
of an incident, and its state of readiness assured?
Facilities:
~ Have facilities capable of performing rapid chemical analyses been identified?
~ Do adequate facilities exist for storage and cleaning/reconditioning of response
equipment?
~ Have locations or facilities been identified for the storage, treatment, recycling,
and disposal of wastes resulting from a release?
~ Do adequate facilities exist for carrying out training programs?
~ Do facilities exist that are capable of providing medical treatment to persons
injured by chemical exposure?
~ Have facilities and procedures been identified for housing persons requiring
evacuation or temporary relocation as a result of an incident?
~ 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.
~ Have the levels of vulnerability and probable locations of hazardous materials
incidents been identified in the plan?
~ Have areas of public health concern been identified in the plan?
~ Have sensitive environmental areas been identified in the plan?
~ For the hazardous material identified in the area, does the plan include informa-
tion on the chemical and physical properties of the material, 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.)
~ Have all appropriate agencies, departments, or organizations been involved in
the process of developing or reviewing the plan?
~ Have all the appropriate agencies, departments, or organizations approved the
plan?
~ Has the organizational structure and notification list defined in the plan been
reviewed in the last six months?
~ Is the organizational structure identified in the plan compatible with the Federal
response organization in the NCP?
~ Has one organization been identified in the plan as having command and control
responsibility for the pre-response, response, and post response phases?
~ Does the plan define the organizational responsibilities and relationships among
city, county, district, State, and Federal response agencies?
~ 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)?
~ 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?
~ 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?
~ Does the plan include a communications system/method to disseminate infor-
mation to responders, affected public, etc.?
Page C-9
-------
~ Has a system been identified in the plan to carry out public information/commu-
nity relations activities?
~ Has a central location or phone number been included in the plan for initial notifi-
cation of an incident?
~ Have trained and equipped incident commanders been identified in the plan?
~ Does the plan include the authority for vesting site decisions in the incident com-
mander?
~ Have government agency personnel that may be involved in response activities
been involved in the planning process?
~ 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?
~ Does the plan provide for frequent training exercises to train personnel or to test
the local contingency plans?
~ Are lists/systems that identify emergency equipment available to response per-
sonnel included in the plan?
~ 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?
~ Does the plan address the potential needs for evacuation, what agency is
authorized to order an evacuation, how it will be carried out, and where people
will be moved?
~ 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?
~ Are there follow-up response activities scheduled in the plan?
~ Are there procedures for updating the plan?
~ Are there annexes 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)?
Page C-10
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APPENDIX D
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.
Cash man, 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 Planning Handbook. Washing-
ton, 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 D-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, 1966.
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 D-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 Superiund: 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.
Kansas State University. A Community Model for Handllnig Hazardous Material Trans-
portation Emergencies. Washington, DC: U.S. Department of Transportation, 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. Washington, DC: U.S. Department of Transportation,
1981.
Urban Systems Associates, Inc., St. Bernard Parish Planning Commission. St. 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.
Page D-3
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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 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. Hazardous Materials Transportation: A Synthesis of
Lessons Learned from the DOT Demonstration Projects. Washington, DC.
Transportation Research Board. Transportation of Hazardous Materials: Toward a National
Strategy. Volumes 1 & 2. Washington, DC: 1983.
Soill 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. Environmental Protection Agency. Standard Operating Safety Guides. Washing-
ton, DC: 1984.
VIDEOTAPES
The following videotapes are available from the Chemical Manufacturers Association:
'How a Coordinating Group Works"
'First on the Scene"
The following videotapes are available from FEMA's National Emergency Training Cen-
ter/Learning Resource Center/Emergency Management Information Center:
~ "Livingston, LA, Hazardous Materials Spills" (September 28, 1982)
~ "Waverly, TN, Hazardous Materials Blast" (February 22, 1978)
~
CAER:
~
CAER:
~
CAER:
~
CAER:
~
NCRIC
Page D-4
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APPENDIX E
FEDERAL AGENCY ADDRESSES
1. NATIONAL OFFICES
Federal Emergency Management Agency
Federal Center Plaza
500 C Street, S.W.
Washington, DC 20472
(202) 646-2400
National Emergency Training Center
Emmitsburg, MD 21727
(301) 447-6771
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
(202) 382-2090
Agency for Toxic Substances
and Disease Registry
Department of Health & Human Services
Chamblee Building 30S
Atlanta, GA 30333
(404) 452-4100
FTS - 236-4100
U.S. Department of Energy
1000 Independence Avenue, S.W.
Washington, DC 20585
(202) 252-5000
Department of Agriculture
Forest Service
P.O. Box 2417
Washington, DC 20013
(703) 235-8018
Department of Commerce
NOAA Superfund Program Coordinator
11400 Rockville Pike
Rockville, MD 20852
(301) 443-8465
Occupational Safety & Health Admin.
Department of Labor
Directorate of Field Operations
200 Constitution Avenue, N.W.
Washington, DC 20210
(202) 523-8063
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 (DOT)
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 State
Office of Oceans and Polar Affairs
Room 5801
2201 C St., N.W.
Washington, DC 20520
(202) 647-3263
Page E-l
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Department of Defense
OASD (A+L)E
Room 3D 833
The Pentagon
Washington, DC 20301-8000
(202) 695-7820
Department of the Interior
18th and C St., N.W.
Washington, DC 20240
(202)343-3891
Nuclear Regulatory Commision
Office of Inspection and Enforcement
7735 Old Georgetown Rd.
Washington, DC 20555
(301) 492-7053
Page E-2
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EPA. FEMA. HHS. ATSDR. OSHA
Regional Offices
U.S. COAST GUARD DISTRICTS
C
Oe
Hi
I
u>
Pacific Area
Atlantic Area
COMPLANTAREA
Department of Energy Regional Coordinating Offices for
Radiological Assistance and Geographical Areas of Responsibility
IV)
s
O
o
o
3
a
CO
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2. REGIONAL OFFICES
A. EPA Regional Offices
Region I
(Connecticut, Maine, Massachusetts,
New Hampshire, Rhode Island, Vermont)
John F. Kennedy Building, Rm. 2203
Boston, MA 02203
(617) 223-7210
Region II
(New Jersey, New York, Puerto Rico,
Virgin Islands)
26 Federal Plaza, Room 900
New York, NY 10278
(201) 264-2525
Region VI
(Arkansas, Louisiana, New Mexico,
Oklahoma, Texas)
1201 Elm Street
Dallas, TX 75270
(214) 767-2600
Region VII
(Iowa, Kansas, Missouri, Nebraska)
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2800
Region III
(Delaware, Washington DC, Maryland,)
Pennsylvania, Virginia, West Virginia)
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-9800
Region IV
(Alabama, Florida, Georgia, Kentucky,
Mississippi, North Carolina,
South Carolina, Tennessee)
345 Courtland, Street, N.E.
Atlanta, GA 30365
(404) 347-4727
Region V
(Illinois, Indiana, Michigan,
Minnesota, Ohio, Wisconsin)
230 S. Dearborn Street
Chicago, IL 60604
(312) 353-2000
Region VIII
(Colorado, Montana, North Dakota,
South Dakota, Utah, Wyoming)
1860 Lincoln Street
Denver, CO 80295
(303) 293-1603
Region IX
(Arizona, California, Hawaii, Nevada,
American Samoa, Guam)
215 Fremont Street
San Francisco, Ca 94105
(415) 974-8153
Region X
(Alaska, Idaho, Oregon, Washington)
1200 6th Avenue
Seattle, WA 98101
(206) 442-5810
Page E-4
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B. FEMA Regional Offices
Region I
(Connecticut, Maine, Massachusetts,
New Hampshire, Rhode Island, Vermont)
442 J.W. McCormack POCH
Boston, MA 02109
(617) 223-4741
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) 556-8794
Region X
(Alaska, Idaho, Oregon, Washington)
Federal Regional Center
130 228th St., S.W.
Bothell, WA 98021-9796
(206) 481-8800
Page E-5
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C. HHS REGIONAL OFFICES
(Note: Consult the map on Page E-2 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 E-6
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D. ATSDR PUBLIC HEALTH ADVISORS ASSIGNED TO
EPA REGIONAL OFFICES
(Note: Consult the map on Page E-2 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) 223-1948
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 Publi^ 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 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 V Region X
ATSDR Public Health Advisor ATSDR Public Health Advisor
Emergency & Remedial Branch (5HR) Hazardous Waste (M/S 525)
230 S. Dearborn 1200 6th Avenue
Chicago, IL 60604 Seattle, WA 98101
(312) 886-0398 (206) 442-2711
Page E-7
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E. OSHA REGIONAL OFFICES
(Note: Consult the map on Page E-2 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 E-8
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F. U.S. Coast Guard District Offices
1st District
(Connecticut, Massachusetts,
New Hampshire, Rhode Island, Vermont)
Commander (mep)
408 Atlantic Avenue
Boston, MA 02110-2209
(617) 223-8444
2nd District
(Alabama, Arkansas, Colorado, Illinois,
Indiana, Iowa, Kansas, Kentucky,
Minnesota, Mississippi, Missouri,
Nebraska, North Dakota, Ohio,
Pennsylvania, South Dakota, Tennessee,
West Virginia, Wyoming)
Commander (meps)
1430 Olive Street
St. Louis, MO 63103
(314) 425-4655
3rd District
(Delaware, New Jersey, New York,
Pennsylvania)
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
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
9th District
(Indiana, Illinois, Michigan, Minnesota,
Ohio, Pennsylvania, New York,
Wisconsin
Commander (mep)
1240 East 9th Street
Cleveland, OH 44199
(216) 522-3918
Commander (mep)
Governors Island
New York, NY 10004
(212) 668-7152
5th District
(Maryland, North Carolina, Virginia)
Commander (mep)
Federal Building
431 Crawford Street
Portsmouth, VA 23705
(804) 398-6638
11th District
(Arizona, California, Nevada, Utah)
Commander (mep)
Union Bank Building
400 Oceangate
Long Beach, CA 90822
(213) 590-2301
Page E-9
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F. U.S. Coast Guard District Offices (Continued)
12th District
(California, Nevada, Utah)
Commander (mep)
Coast Guard Island
Alameda, CA 94501
(415) 437-3465
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,
Northern Mariana Islands)
Commander (mep)
Prince Kalanianaole Federal Building
300 Ala Moana Boulevard, 9th Floor
Honolulu, HI 96850
(808) 546-7510
17th District
(Alaska)
Commander (mep)
P.O. Box 3-5000
Juneau, AK 99802
(907) 586-7195
Page E-10
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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 7digit 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 7digit 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 7digit 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 E-ll
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