Environmental Protection
Agency
Superfund
Solid Waste and
Emergency Response
EPA/540/R-95/130
PB96-963201
January 1995
Inland Area Contingency PI 311
Region IV
Alabama
Florida
Georgia
Kentucky
Mississippi
N. Carolina
S. Carolina
Tennessee
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FEDERAL REGION IV
OIL AND HAZARDOUS SUBSTANCES POLLUTION
REGIONAL AND AREA CONTINGENCY PLAN
UPDATE - JAN. 1995
W
on. a hazardous suasTANCM
EMERGENCY RESPONSE
L AND
1 REMOVAL
U.S. DEPARTMENT OF TRANSPORTATION
UNITED STATES COAST GUARD
SEVENTH COAST GUARD DISTRICT
BRICKELL PLAZA FEDERAL BUILDING
909 S.E. FIRST AVENUE
MIAMI, FLORIDA 33131-3050
ENVIRONMENTAL PROTECTION AGENCY
FEDERAL REGION IV
EMERGENCY RESPONSE AND REMOVAL BRANCH
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
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Federal Region IV
United Stales
Coast Guard
Environmental
Protection Agency
Department of
'Agricultur s
Department of
" Commerce
Department of
Defense
Department of
Energy
Department of
Health and Human
Services
Department of
Interior
Department of
Justice
Department of
Labor
Department of
State
federal Emergency
¦ianagement Agency-
General Services
Administrator.
Nuclear Regidatory
Commission
Tennessee Valley
Authority
State of
Alabama
State of
Florida
State of
Georgia
Commor.vjsalth of
Kentucky
State of
Mississippi
State of
North Carolina
State of
South Carolina
State of
Tennessee
LETTER OF PROMULGATION FOR THE
REGION IV REGIONAL CONTINGENCY PLAN
The Federal Region IV Oil and Hazardous Substances Regional
Contingency Plan (RCP) has been revised and is published in accordance
with the following:
The Comprehensive Environmental Response Compensation
and Liability Act of 1980, as amended.
The Federal Water Pollution Control Act of 1372, as
amended.
The National Oil and Hazardous Substances Contingency
Plan (NCP), 40 CFR Part 300, September 15, 1994.
This Plan incorporates the USEPA Inland and US Coast Guard Coastal
RCPs, and stands in replacement of both, It is the mechanism for
coordinating responses to oil and hazardous substance releases and
removal activities within the boundaries of Federal Region IV.
This Plan is effective upon receipt and supersedes all previous plans in
their entirety.
Comments and recommendations regarding the Plan should be addressed
tojeitfier Co^^nr of the Regional Response Team.
Myron D.
USEPA Hi |ioh IV
Co-chair
Date
CAPT Gerald W. Abrams Date
Seventh USCG District
Co-chair
Commander (m), Seventh Coast Guard District
909 S.E. First Ave. Rm 90S. Miami, FL 331-3050
(305) 536-5651 / FAX 536-5091
Chief, Emergency Response and Removal Bran
II. S. Environmental Protection Agency, Region
345 Courtlcnd St, Atlanta, GA 30365 r
(404)347-3931 / FAX 347-4454 I
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TABLE OF CONTENTS
SECTION 100. INTRODUCTION
101. PURPOSE
102. AUTHORITY
103. SCOPE
104.
105.
106.
106.1. Hierarchy of Plans
106.2. Federal Planning - National Level
106.3. Federal Planning - Regional Level
106.4. State and Local Government Plans
106.5. Business and Industry Facility Response Plans
107. DISPERSANT and OTHER CHEMICALS USE POLICY .
SECTION 200. ORGANIZATION AND RESPONSIBILITIES
201. INTRODUCTION
202. ORGANIZATIONS
202.1. National Response Team
202.2. Regional Response Team
202.3. Area Committees
202.4. Sensitive Environmental and Economic Areas
203. RESPONSIBILITIES
203.1. On-Scene Coordinators
203.2.
203.3.
203.5.
203.6.
203.7.
SECTION 300. COh
301. GENER;
302. MULTIF
303. REMOV
SECTION 400. ADMINIS1
401. REPOR1
402. RECORI
403. FUNDUS!
404. IAGsAI
SECTION 500. DIRE
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ANNEX A: SPILL RESPONSE ORGANIZATION AND COMMAND ... A-1 (1/95)
Purpose and Scope A-1 (1/95)
Procedures A-1 (1/95)
A Spill Scenario . . . A-1 (1/95)
Unified Command A-2 (1/95)
INCIDENT OSC A-5 (1/95)
Scope A-5 (1/95)
Primary Agency A-5 (1/95)
Support Agencies A-5 (1/95)
Responsibilities A-6 (1/95)
DISCHARGER A-8 (1/95)
STATE AND LOCAL REPRESENTATIVES A-9 (1/95)
REGIONAL RESPONSE TEAM A-11 (1/95)
NATURAL RESOURCES DAMAGE ASSESSMENT A-14 (1/95)
INCIDENT OSC STAFF A-15 (1/95)
Deputy OSC A-15 (1/95)
Safety Coordinator A-16 (1/95)
Public Affairs Liasion A-18 (1/95)
Documentation Coordinator A-19 (1/95)
FINANCE A-20 (1/95)
Finance Officer A-20 (1/95)
Claims Coordinator A-21 (1/95)
Enforcement Coordinator A-22 (1/95)
Procurement Coordinator A-23 (1/95)
Cost Tracker A-24 (1/95)
LOGISTICS A-25 (1/95)
Logistics Officer A-26 (1/95)
Resource Coordinator A-27 (1/95)
Personnel and Volunteer Coordinator A-28 (1/95)
Transportation Coordinator A-29 (1/95)
Training Coordinator A-30 (1/95)
Communications Coordinator A-31 (1/95)
Security Coordinator A-32 (1/95)
PLANNING A-33 (1/95)
Planning Officer A-33 (1/95)
Advance Teams Coordinator A-34 (1/95)
How Clean is Clean? Team A-36 (1/95)
Disposal Coordinator A-37 (1/95)
Scientific Support Coordinator A-38 (1/95)
OPERATIONS A-41 (1/95)
Operations Officer A-42 (1/95)
Clean-up Teams Coordinator A-43 (1/95)
Wildlife Recovery Coordinator A-45 (1/95)
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ANNEX B: NOTIFICATION, COMMUNICATION, REPORTS B-1
Purpose B-1
Scope B-1
Responsibilities B-1
NOTIFICATION AND ACTIVATION PROCEDURES B-1
COMMUNICATION PROCEDURES B-2
On-Scene Communications B-2
During incident B-3
REPORTS PROCEDURES . . B-4
APPENDIX B-1: Classification of releases B-1-1
Oil Releases B-1-1
Hazardous Substances B-1-2
APPENDIX B-2: Notification Situations B-2-1
APPENDIX B-3: Activation of the RRT B-3-1
APPENDIX B-4: Pollution Reports B-4-1
TAB B4-A: Damage Assessment/Tracking Form B-4-2
TAB B4-B: Pollution Reports B-4-3
TAB B4-C: 311(b)(3) Documentation B-4-7
TAB B4-D: OSC Report B-4-8
TAB B4-E: Debriefing/Critique B-4-13
ANNEX C: RESPONSE STRATEGIES C-1
Purpose and Scope C-1
RESPONSE PRIORITIES C-1
Responsibilities C-2
DEVELOPING A STRATEGY C-2
GUIDELINES C-4
APPENDIX C-1: Types of Oil C-1-1
APPENDIX C-2: Types of Environments Impacted C-2-1
APPENDIX C-3: Methods to Reduce Overall Impact C-3-1
TAB C-3a: Physical Containment C-3-1
TAB C-3b: Physical Removal C-3-2
TAB C-3c: Chemical Oil Stabilizers C-3-3
TAB C-3d: De-emulsifying Agents C-3-3
TAB C-3e: Dispersants C-3-4
TAB C-3f: Surface Collecting Agents C-3-4
TAB C-3g: In-situ Burning C-3-5
TAB C-3h: Bioremediation C-3-6
Clean Up Technologies C-4-1
APPENDIX C-5: National Product Schedule . C-5-1
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ANNEX D: REGIONAL RESPONSE RESOURCES D-1
Purpose D-1
Scope D-1
Responsibilities D-1
PROCEDURES . D-3
ANNEX E: COMMUNICATIONS E-1
Purpose E-1
Scope E-1
Responsibilities E-1
PROCEDURES E-2
CAPABILITIES/EQUIPMENT AVAILABLE E-3
ANNEX F: SENSITIVE ENVIRONMENTAL & ECONOMIC AREAS F-1
Purpose F-1
Scope F-1
Responsibilities F-2
Procedures F-3
DESCRIPTION OF SENSITIVE AREAS F-4
APPENDIX F-1: Endangered Species Information F-7
APPENDIX F-2: Critical Habitat Catalog F-7
Additional Information Sources F-7
Summary of 40 CFR PART 112 F-9
ANNEX G: WORKER HEALTH AND SAFETY G-1
Purpose G-1
Scope G-1
Responsibilities G-1
Procedures G-3
APPENDIX G-1: Generic Site Safety Plan G-1-1
ANNEX H: FUNDING AND CONTRACTING H-1
Purpose H-1
Scope H-1
Responsibilities and Procedures H-1
Funding H-1
Contracting H-2
ANNEX l: PUBLIC INFORMATION 1-1
Purpose 1-1
Scope ,1-1
Responsibilities 1-1
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Procedures .1-2
Initial 1-2
Media Relations 1-3
Community Relations 1-3
Internal Information 1-4
VIP Relations 1-4
Academic Interests and Product Sales Reps 1-4
METHODS FOR INFORMING THE PUBLIC . . I-S
APPENDIX 1-1: Fact Sheets and Press Releases 1-1-1
APPENDIX I-2: Meetings and Briefings 1-2-1
APPENDIX I-3: Joint Information Center . 1-3-1
ANNEX K: DISPOSAL K-1
Purpose K-1
Scope K-1
Responsibilities . K-1
Procedures K-2
WASTE STREAM IDENTIFICATION K-2
DISPOSAL OPTIONS . K-3
TREATMENT OPTIONS K-4
ADDITIONAL CONSIDERATIONS K-5
ANNEX L: POTENTIAL SPILL SOURCES L-1
ANNEX M: MOUs FOR GEOGRAPHIC BOUNDARIES M-1
Purpose and Scope M-1
APPENDIX M-1: Boundary Map for US Coast Guard Districts M-1-2
APPENDIX M-2: MOU-USCG Second District, Missouri M-2-3
APPENDIX M-3: MOU-USCG Fifth District, North Carolina M-3-5
APPENDIX M-4: MOU-USCG Seventh District, Florida M-4-6
APPENDIX M-5: MOU-USCG Eighth District, Louisianna M-4-8
APPENDIX M-6: Boundary Map for USEPA Regions M-6-10
APPENDIX M-7: MOU-USEPA REGION III, Philadelphia M-6-11
APPENDIX M-8: MOU-USEPA REGION V, Chicago M-6-13
APPENDIX M-9: MOU-USEPA REGION VI, Dallas M-6-15
APPENDIX M-10: MOU-USEPA REGION VII, Kansas City M-6-18
ANNEX N: lAGs and MOUs N-1
Purpose and Scope N-1
APPENDIX N-1: MOU-USCG and USEPA - Damage Mitigation N-2
APPENDIX N-2: MOU-USCG and USEPA - Funding Vendor Costs . N-2-3
APPENDIX N-3: IAG-DOT and USEPA N-3-6
APPENDIX N-4: INSTRUMENT OF REDELEGATION N-4-7
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APPENDIX N-5: IAG- USAGE and USEPA . N-5-8
APPENDIX N-6: MOU-DOD and USEPA N-6-10
APPENDIX N-7: MOU-ATSDR and USEPA .... N-7-13
APPENDIX N-8: MOU-DOI and USEPA N-8-17
APPENDIX N-9: MOU-GSA and USEPA and USCG N-9-20
APPENDIX N-10: USEPA, USCG and State of Florida N-10-24
APPENDIX N-11: MOU-TVA and USEPA N-11-26
ANNEX 0; PREDESIGNATED ON-SCENE COORDINATORS 0-1 (1/95)
ANNEX P (Coordination Draft): ESF-#10 ESF-10-1 (1/95)
ANNEX Q (Draft): RESPONSES TO RADIOLOGICAL INCIDENTS ... R-1 (1/95)
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ACRONYMS
ACP - Area Contingency Plan
APHIS - Animal and Plant Health Inspection Service
ASCS - Agricultural Stabilization and Conservation Service
ATSDR - Agency for Toxic Substances and Disease Registry
BIA - Bureau of Indian Affairs
BLM - Bureau of Land Management
BOA - Basic Ordering Agreement
BOM - Bureau of Mines
BOR - Bureau of Reclamation
CAAA - Clean Air Act Amendments
CAS - Chemical Abstract Service
CDC - Center for Disease Control
CEMP - Comprehensive Emergency Management Plan
CERCLA-Comprehensive Environmental Response, Compensation and
Liability Act
CO - Contracting Officer
COTP - Captain of the Port
CRC - Community Relations Coordinator
CWA - Clean Water Act
DOC - Department of Commerce
DOD - Department of Defense
DOE - Department of Energy
DOI - Department of the fnterior
DOJ - Department of Justice
DOL - Department of Labor
DOS - Department of State
DOT - Department of Transportation
EOP - Emergency Operations Plan
ERCS - Emergency Response Cleanup Service
ERRB - Emergency Response and Removal Branch
ERT - Environmental Response Team
ESD - Environmental Services Division
ESF - Emergency Support Function
FAR - Federal Acquisition Regulation
FCO - Federal Coordinating Officer
FEMA - Federal Emergency Management Agency
FESC - FEMA Emergency Support Capability
FNS - Food and Nutrition Service
FPN - Federal Project Number
FR - Federal Register
FRERP - Federal Radiological Emergency Response Plan
FRMAP - Federal Radiological Monitoring and Assessment Plan
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FRP - Federal Response Plan or Facility Response Plan
FSIS - Food Safety and Inspection Service
FWPCA - Federal Water Pollution Control Act
GIS - Geographic Information System
GSA - General Services Administration
HAZWOPER - Hazardous Waste Operation and Emergency Response
HHS - Department of Health and Human Services
HQ - Headquarters
IAG - Interagency Agreement
IOC - Incident Operations Center
JIC - Joint Information Center
LEPC - Local Emergency Planning Committee
MATTS - Mobile Air Transportable Telecommunications System
MERS - Mobile Emergency Response Support
MLCLANT - USCG Maintenance and Logistics Command
MOU - Memorandum of Understanding
MRV - Multi-Radio Van
MS - Media Spokesperson
MSO - Marine Safety Office
NASS - National Agricultural Statistics Service
NCLP - National Contract Laboratory Program
NCP - National Contingency Plan
NOAA - National Oceanic and Atmospheric Administration
NPL - National Priority List
NPS - National Park Service
NRC - National Response Center
NRS - National Response System
NRT - National Response Team
NSFCC - National Strike Force Coordination Center
NucRegComm - Nuclear Regulatory Commission
OAM - Office of Acquisition Management
OCA - Office of Congressional Affairs
OPA - Oil Pollution Act
OPAff - Office of Public Affairs
ORD - Office of Research and Development
ORP - Office of Radiological Programs
ORSANCO - Ohio River Valley Water Sanitation Commission
OSC - On-Scene Coordinator
OSEG - Oil Spill Enforcement Guidelines
OSHA - Occupational Safety and Health Administration
OSLTF - Oil Spill Liability Trust Fund
OSRO - Oil Spill Response Organization
PA - Preliminary Assessment
PAH - Polyaromatic Hydrocarbon
PI AT - Public Information Assistance Team
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PO - Protocol Officer
POLREP - Pollution Report
PSM - Process Safety Management
RAT - Radiological Assistance Team
RCP - Regional Contingency Plan
RCRA - Resource Conservation and Recovery Act
REAC - Research, Engineering and Analytical Contracting
REO - Regional Environmental Office
RERT - Radiological Emergency Response Team
RICT - Regional Incident Coordination Team
RMP - Risk Management Plan
RP - Responsible Party
RPM - Remedial Project Manager
RQ - Reportable Quantity
RRC - Regional Response Center
RRT - Regional Response Team
SARA - Superfund Amendments and Reauthorization Act
SERC - State Emergency Response Commission
SITREP - Situation Report
SPCC - Spill Prevention Control and Countermeasures
SSC - Scientific Support Coordinator
SST - Scientific Support Team
TAT -Technical Assistance Team
TDD - Technical Direction Document
TEL - Telephone Duty On-Scene Coordinator
TV A - Tennessee Valley Authority
USACE - US Army Corps of Engineers
UCS - Unified Command System
USCG - US Coast Guard
USDA - US Department of Agriculture
USEPA - US Environmental Protection Agency
USFS - US Forest Service
USFWS - US Fish and Wildlife Service
USGS - US Geological Survey
USPHS - US Public Health Service
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r
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET, N.E.
ATLANTA. GEORGIA 30365
LETTER OF PROMULGATION FOR THE
US EPA REGION IV AREA CONTINGENCY PLAN
Section 4202 of the Oil Pollution Act of 1990 (OPA) amended Section 311 (j) of the
Federal Water Pollution Control Act (FWPCA) {33 U.S.C. 1321 (j)) to address the
development of a National Planning and Response System. As part of this system,
Area Committees are to be established for each area designated by the President.
These committees are to be comprised of qualified personnel from Federal, State and
local agencies. The functions of appointing Area Committee members, determining
the information to be included in Area Contingency Plans, and reviewing and
approving Area Contingency Plans have been delegated by Executive Order 12777 of
22 October 1991, to the Administrator of the United States Environmental Protection
Agency (USEPA) for the inland zone. On April 24, 1992, the United States
Environmental Protection Agency Administrator designated the 13 Regional Response
Teams as Area Committees. The area for this plan has been designated as USEPA
Region IV (Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South
Carolina, Tennessee). The USEPA Region IV Regional Response Team (RRT) serves
as the Area Committee.
This plan has been designed and prepared to satisfy all statutory and regulatory
requirements mandated in the National Contingency Plan (NCP) and OPA. Comments
and recommendations are invited and should be addressed to Mary Jo Bragan, Area
On-Scene Coordinator, United States Environmental Protection Agency, Region IV,
345 Courtland Street, Atlanta, Georgia, 30365. This plan will be reviewed and
updated annually (on January 31) for the first five years of the Plan, and once every
five years after that. Changes or corrections will be published as necessary.
FEB
)ivision Director
US Environmental Protection Agency
Region IV
Date
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HOW TO USE THIS PLAN
This Plan has been prepared to meet ail planning requirements for response to
hazardous substances and oil spills, including those of the Oil Pollution Act of
1990 (OPA), Federal Response Plan (FRP) and the National Contingency Plan
(NCP), To facilitate use during a response, this Plan contains a Base Plan, which is
the Region IV Regional Contingency Plan (RCP), and several Annexes, which when
combined with the Base Plan make up the Area Contingency Plan (ACP). The Base
Plan or RCP is general in nature, presents information and policies that are not
subject to frequent change and outlines the standard strategy to be employed in
responding to releases of oil and hazardous substances. The concepts of
administration, logistics, direction and control are also presented. The Base Plan
serves as the foundation for the Annexes, Appendices, Tabs and Checklists
included in this Plan.
Although containing general response procedures, the Base Plan is not intended to
be used in the field. The Annexes and supporting Appendices and Tabs serve as
specific response guides and provide details for who does what, when, how and
with what. For spills under OPA, the Annexes serve as the ACP and outline
response procedures for a worst-case discharge. The following annexes: Spill
Response Organization and Command; Logistics; Communications and Disposal are
designed to be used as stand-alone documents by the On-Scene Coordinators
(OSC) in the field. Other annexes provide detailed information necessary to
support response operations.
The response is organized functionally along a Unified Command System {UCS)
structure which includes planning, operations, logistics and finance. In any
incident in which two or more levels of government or the responsible party
respond, the UCS will be initiated at a designated command post and the
representatives will meet to develop an Incident Action Plan which outlines the
tactics and objectives to be employed to protect lives, property, the environments
and discusses the removal, cleanup and disposal of recovered material.
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SECTION 100. INTRODUCTION
101. PURPOSE:
This Regional Contingency Plan (RCP) is prepared to comply with the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP) and to implement the
NCP at the Regional level. The plan provides the structure and mechanisms for
responding to a pollution incident, or threat of a pollution incident, in a timely,
coordinated and effective fashion. Procedures for coordinating with the United
States Coast Guard (USCG) Area Plans and other Federal, state, tribal and local
community emergency plans are presented in this plan.
102. AUTHORITY:
Section 300.210 of the NCP, promulgated in accordance with the requirements of
the Federal Water Pollution Control Act (FWPCA) as amended, and Section 105 of
the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA) requires that each standard Federal region develop a RCP to coordinate
preparation and assistance activities both before and during a spill response.
Section 4202 of the Oil Pollution Act of 1990 (OPA), which amends Subsection (j)
of Section 311 of the FWPCA as amended by the Clean Water Act (CWA) of
1977, requires the development of Area Contingency Plans for responding to a
worst-case oil discharge. Pursuant to OPA section 4202(b)(1)(A), the President
designates areas for which Area Contingency Plans are established. Through
section 1(b) of Executive Order 12777 (56 FR 54757; October 22, 1991), the
President delegated to the Administrator, United States Environmental Protection
Agency (USEPA), responsibility for designating the Areas and appointing the
Committees for the "Inland Zone" as defined by the NCP. The USCG has
responsibility for designating Areas and appointing Committees for the coastal zone
as defined by the NCP. The USEPA Administrator, in 57 Federal Register (FR)
15198; April 24, 1992 designated the inland areas of the 13 Regional Response
Teams (RRT) as the designated Areas and the 13 individual RRTs as the Area
Committees. In the same FR Notice, the USCG designated as Areas, those
portions of the Captain of the Port (COTP) zones within the coastal zone as defined
in the NCP as the designated Area. The precise boundaries for the inland and
coastal zones are described in Annex M.
103. SCOPE:
The NCP authorizes the USEPA and USCG to undertake removal measures deemed
necessary to protect the public health or welfare or the environment from
discharges of oil or releases of hazardous substances, pollutants, or contaminants.
1 (update JAN 1995)
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This plan is applicable to response actions taken pursuant to the authorities under
CERCLA and Section 311 of the CWA, as amended. The strategies, mechanisms,
operations and procedures contained in this plan conform with the provisions of
the NCP.
This plan is a combined coastal and inland zone RCP governing Federal response
operations to threats and/or discharges of oil in the inland zone or to releases or
threats of releases of hazardous substances in both zones. As the chief working
document of the RRT and the ACP for the inland zone of the Region, this Plan
meets the provisions of all statutory and regulatory requirements for such plans,
including Region IV's strategy to address worst-case oil discharges, Federally
declared disasters and significant hazardous substance releases.
The following Region IV classifications are used for oil and hazardous substance
releases occurring in the inland zone:
TYPE
OIL
HAZ. SUBSTANCE
MINOR
< 1,000 gallons
< Reportable Quantity
MEDIUM
1,000-10,000
gallons
> Reportable Quantity
but doesn't meet criteria for a
major or minor release
MAJOR
> 10,000 gallons
amount that poses a
substantial threat to human
health, welfare
or environment
WORST CASE
a worst case involves ANY discharge or threat of a discharge, in
significant quantities to impact public health, welfare or the
environment, where the parties responsible for the threat or
discharge are unwilling or unable to perform the required response
actions.
Within this plan are the appropriate coordination mechanisms to ensure
compatibility and coordination with the ACPs developed by the USCG COTP for
responding to discharges of oil within the coastal zone and with the Federal
Response Plan (FRP) written by the Federal Emergency Management Agency
(FEMA) for responding to natural disasters.
This plan has been developed with the cooperation of all designated USEPA
agencies and state and local governments. It applies to all preparedness activities
and response operations taken by the Federal member agencies of the Region IV
RRT. The geographical boundaries of this plan are those defining standard
Federal Region IV and include the states of Alabama, Florida, Georgia, Kentucky,
Mississippi, North Carolina, South Carolina and Tennessee.
2 (update JAN 1995)
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This plan is applicable to and is in effect for:
(1) Discharges of oil into or on the navigable waters and adjoining shorelines of
the United States that lie within the inland zone of the region as defined in
this plan. When discharges of oil into or on the navigable waters and
adjoining shorelines or other waters as defined in the appropriate USCG
ACP, the response will be managed under that applicable ACP.
(2) Releases into the environment of the inland zone, of hazardous substances,
and pollutants or contaminants which may present an imminent and
substantial danger to public health or welfare. When releases or threats of
releases of hazardous substances occur within the jurisdiction of a USCG
designated area and the applicable ACP contains provisions for a response to
such a release, that ACP shall govern the response to that release.
(3) Additional resource and support requirements above those available through
the applicable COTP ACP will be coordinated through the provisions of this
plan and the NCP as needed.
This plan will be used to:
(1) Identify primary responsibilities and jurisdictions among Federal, State, tribal
and local governments in response actions.
(2) Describe Federal response actions in accordance with the CWA and
CERCLA.
(3) Describe Area Response Planning concepts and Committee membership in
Region IV.
(4) Describe methods and procedures to coordinate and integrate multi-agency,
multi-area and multi-regional responses and plans.
(5) Provide information concerning facilities, resources, equipment and
additional capabilities from governmental, commercial, academic and other
sources.
(6) Provide information pertaining to preparedness activities including planning,
training and exercising.
3 (update JAN 1995)
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104. ASSUMPTIONS:
* Threats and releases of hazardous substances and discharges of oil occur within
the inland and coastal areas of the region requiring Federal response actions.
* Upon notification of a spill or threat of a spill, the procedures and coordination
mechanisms in this plan will be followed, as necessary, to implement a Federal
response in support of local and state government actions.
* Regional response forces respond with all applicable and available resources
when releases of hazardous substances, discharges of oil or other pollution or
contamination incidents require a Federal response presence.
* Natural disasters and technological emergencies that occur in the Region will
cause the activation of the FRP. This plan provides the coordination
mechanisms to integrate appropriate Regional response actions into the Federal
Response Plan structure.
* A Federal response under this plan will not be immediately initiated at the scene
of an incident. Travel time may prevent a Federal OSC from arriving on-scene in
the first eight to ten hours following an incident. The arrival of response
resources may take even longer.
105. RESPONSE POLICY:
It is the policy of the Region IV RRT that response actions on non-Federal lands be
monitored or implemented by the lowest level of government with authority and
capability to conduct such activities. Generally, the lowest level is the local
government agencies. When the discharge is beyond the response capabilities of
the local or state agencies, or sufficient removal operations are not being
conducted to protect the population and environment, the Federal OSC will initiate
the appropriate Federal response action. Region IV's unified command protocol for
response actions under this plan is presented in Annex A.
To ensure maximum coordination and utilization of response resources, the
designated State contact will communicate as soon as possible with the Federal
OSC following an incident that requires or that could potentially require immediate
attention. If insufficient information is available through the State contact, the
OSC can communicate directly with local officials. Once as much information is
gathered as possible, the OSC may respond on-site to further assess the situation.
The responsible party (RP) for the discharge or release, or threat of a discharge or
release, must take immediate and effective actions to mitigate the effects of any
spill and to cleanup and restore the incident site. The actions of the RP shall be
consistent with the provisions outlined in this plan, the NCP and, if applicable, the
RP's Facility Response Plan.
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Facility Response Plans, as defined by Section 4204(a)(1) of OPA, shall be
reviewed for approval and consistency with this Plan. During a response the OSC
shall meet with other responding parties to coordinate and integrate this Plan with
all other relevant plans including, but not limited to, Federal, State, local, tribal, and
private plans. The RRT will continuously review effectiveness and integration of all
plans based on actual responses, exercises, and all other relevant information
leading to enhancement of these plans.
106. RELATIONSHIPS WITH OTHER PLANS:
106.1. Hierarchy of Plans
This section identifies emergency response plans at all levels of government, as
well as those prepared by facilities, for coordination and operation between
response agencies. The technical nature and unique demands of chemical and oil
emergencies forces private, local, state and federal levels to prepare response
plans. At the Federal level are national, regional and area contingency response
plans. At the State and Local level are state, regional, local, departmental and
support-agency plans. And within the private sector, OPA, CERCLA and OSHA
require industrial facilities to prepare contingency plans. Each of these plans
reflect responsibilities and levels of action to be performed by actual emergency
responders. Given the fact that responses to oil and hazardous substance
incidents are multi-organizational and multi-jurisdictional, a basic understanding of
the various plans operating in a response is needed to facilitate effective
integration and coordination.
106.2. Federal Planning - National Level
106.201 THE NATIONAL OIL AND HAZARDOUS SUBSTANCES POLLUTION
CONTINGENCY PLAN (NCPI
The NCP provides the overall structure and procedures for preparing for and
responding to discharges of oil and releases of hazardous substances, pollutants
and contaminants. The NCP, found in the Code of Federal Regulations at 40 CFR
300, provides authority for direct federal response to spills of oil and hazardous
substance discharges. The regulatory base makes the NCP unique because it
carries the force of law and identifies statutory requirements for response and
preparedness. Responsibility for NCP maintenance has been delegated to USEPA.
Provisions of the NCP include: guidelines for development of federal, regional and
area contingency plans; approval procedures for dispersant, in-situ burning and
other chemical agents use; procedures for undertaking response actions pursuant
to CERCLA and Section 311 of the CWA; specification of responsibilities for
Federal, State and Local governments; and, requirements for State and Local
emergency planning requirements under SARA Title III.
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106.202. FEDERAL RESPONSE PLAN (FRP1
The FRP provides for federal response in support of State and Local governments
to disaster situations. Annex 10 of the FRP, Emergency Support Function (ESF)
#10, integrates the NCP's authority to respond to discharges and releases of oil
and hazardous substances with a natural disaster response. The NCP applies to
and is in effect when the FRP and some or all of its ESF are activated. Annex P,
entitled ESF #10 Operations, details coordination procedures and describes the
operations taken under this plan with those under the FRP.
106.203. FEDERAL RADIOLOGICAL EMERGENCY RESPONSE PLAN fFRERPt
The FRERP is activated during any peacetime radiological emergency that is or will
be expected to have a significant radiological effect in the United States. Where
appropriate, the lead or support federal agency shall act consistent with the
notification and assistance procedures described in the FRERP. USEPA's Office of
Radiation Programs has established Radiological Emergency Response Teams
(RERTs) for response support for incidents or sites containing radiological hazards.
Most radiological releases do not result in FRERP activation and as a result are
handled in accordance with NCP. However, certain releases of nuclear materials
regulated by the Nuclear Regulatory Commission are specifically excluded from
CERCLA and NCP requirements.
106.3. Federal Planning - Regional Level
Subpart C of the NCP describes the levels of contingency planning under the
National Response System and cross-references State and Local emergency
preparedness activities under SARA Title III. Within each of the Federal Regions,
two levels of federal planning take place, the RCP and the ACP.
106.301. REGIONAL OIL AND HAZARDOUS SUBSTANCES POLLUTION
CONTINGENCY PLAN (RCPt
The NCP requires each Federal region, through the collective efforts of the RRT
and the States, develop a RCP which outlines how organizations will effectively
respond to releases or discharges of oil or hazardous substances, pollutants or
contaminants. The RRT provides the mechanism for planning and coordinating
preparedness and response actions as well as maintaining the RCP.
106.302. AREA CONTINGENCY PLANS (ACPI
The Oil Pollution Act (OPA) of 1990 requires the development of ACPs for
discharges of oil and hazardous substances as designated in the Clean Water Act
(CWA). The ACPs when implemented in conjunction with other provisions of the
NCP and RCP, must be adequate to remove a worst case discharge and to mitigate
or prevent a substantial threat of such a discharge. ACPs provide for a well
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coordinated response that is integrated and compatible to the greatest extent
possible, with all appropriate response plans of State, Local and non-federal
entities, especially Title III Local Emergency Response Plans.
Area Committees, under the direction of an OSC, develop the ACPs for the
designated areas. Made up of Federal, State, Local and private representatives the
Area Committees are planning and preparedness entities that do not have
operational decision authority. The ACP however, contains the mechanisms and
pre-authorizations to approve response options such as dispersants or in-situ
burning.
The RCP for Federal Region IV is also the ACP for the inland area of the region.
The designation of the inland area was made by the USEPA Administrator in April
1992. As a region wide planning and support coordination plan, this RCP is
applicable for both the coastal and inland zones as the umbrella plan for the region
and applies to discharges of oil and to releases of hazardous substances. The plan
also contains the mechanisms to provide resource coordination in support of the
ACP.
106.4. State and Local Government Plans
106.401. STATE COMPREHENSIVE EMERGENCY MANAGEMENT PLAN (CEMP)
State CEMPs, sometimes called a comprehensive emergency operations plan (EOP),
are generally multi-hazard plans developed by the State Emergency Management
Agency to coordinate the responses and response support activities of State
agencies in both natural and technological emergency and disaster situations.
106.402. STATE ENVIRONMENTAL AGENCY OIL AND HAZARDOUS
SUBSTANCES RESPONSE PLANS
Several of the States in the region have statutes that establish the State
environmental agency as the "lead agency" for oil and hazardous substance
emergency responses. These agencies have developed departmental plans for on-
scene response operations to provide the appropriate steps for achieving a safe
and efficient management of the environmental aspects of the emergency.
106.403. LOCAL/COMMUNITY EMERGENCY OPERATIONS PLANS
The local CEMP or EOP describes the jurisdiction's response to the threats that
exist within the community. These plans range from excellent comprehensive
multi-hazard plans to relics left over from old Civil Defense plans dealing with
nuclear attack. Local EOPs provide the guidance necessary for coordinated action,
including direction and control and the assignment of emergency forces and
resources.
SARA Title III required each Local Emergency Planning Committee to prepare an
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emergency response plan to address the hazards that extremely hazardous
substances pose to the community. While these are "single-hazard" plans, many
jurisdictions have Incorporated these plans into the community EOP or have used
the Title 111 process to drive the development of a multi-hazard plan.
106.404. DEPARTMENTAL AND SUPPORT AGENCY PLANS
Plans developed by individual local public safety agencies (fire, law enforcement,
public works, emergency medical) and other local support agencies define each
department's emergency response structure, operation procedures and details of
the department's response. Such plans typically profile contingencies,
notification/actions, detailed response procedures, equipment lists, resources and
field techniques. The response actions of these individual response/support agency
plans are coordinated through the community CEMP or EOP and managed through
the local Incident Command System.
106.5. Business and Industry Facility Response Plans
Many businesses and industrial facilities including vessels that use, store, treat,
transport or otherwise handle oil, hazardous substances or hazardous wastes are
required by Federal law to prepare emergency or contingency plans to protect their
employees and the surrounding communities from fires, explosions and releases of
these products. A brief outline of these plans and the facilities required to prepare
them follows:
106.501. HAZARDOUS WASTE TREATMENT. STORAGE AND DISPOSAL
FACILITIES. 40 CFR PART 264.50
Regulations implementing the Resource Conservation and Recovery Act (RCRA)
require owners and operators of hazardous waste facilities to prepare a
contingency plan that is designed to minimize the hazards to human health or the
environment from fires, explosions or any unplanned release of hazardous wastes.
These plans must be coordinated with local response agencies as well as State and
Local emergency response teams. Hie plan must also name an emergency
coordinator, include a list of emergency equipment at the facility and define the
emergency procedures to be followed.
106.502. FACILITY/VESSEL RESPONSE PLANS
The Oil Pollution Act of 1990 requires that certain facilities as well as tank vessels,
which handle, store, transfer or transport oil, prepare a facility or vessel response
plan. The implementing regulations that apply to on-shore non-transportation
related facilities are promulgated by USEPA at 40 CFR 112. On-shore
transportation related facilities and tank vessels transporting oil are regulated by
the USCG. Pipelines are regulated by the Office of Pipeline Safety which is a part
of the Research and Special Programs Administration in the Department of
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Transportation, The response plans, developed in accordance with the regulations
issued by these agencies, must be consistent with the NCP and the applicable
ACP. The plan must also identify the qualified individual with authority to
implement removal actions, identify private personnel and equipment necessary to
remove, to the extent possible, a worst case discharge and describe training,
equipment testing, exercises and response actions of persons on the vessel or at
the facility.
106.503. SPILL PREVENTION CONTROL & COUNTERMEASURES (SPCC) PLANS
The Oil Pollution Prevention regulation, mandated by the Clean Water Act,
establishes procedures, methods and equipment requirements to prevent the
discharge of oil. The SPCC Plans are prevention oriented rather than response
oriented. The plans must show that containment, diversionary structures and
equipment are in place to prevent discharged oil from reaching a navigable water
course. This requirement also includes a secondary means of containment of bulk
storage tanks and other requirements pertinent to loading/unloading facilities and
transfer operations, security considerations, personnel training and spill prevention
procedures.
106.504. CLEAN AIR ACT AMENDMENTS (CAAA) - FACILITY RISK
MANAGEMENT PLANS (RMPl
The CAAA provisions for accident prevention ensures that facilities take steps to
reduce the likelihood and severity of accidental chemical releases that could harm
the public and the environment. The substances identified are those that have the
greatest potential to pose a hazard to public health and the environment. A facility
that stores, manufactures, handles or otherwise uses more than a threshold
quantity of a listed substance must develop a RMP. This plan must include off-site
consequence analysis, a 5-year accident history, a prevention program and an
emergency response program. The written emergency response plan includes
specific actions to be taken in response to an accidental release of a regulated
substance to protect human health and the environment. It must also include
procedures to notify response agencies, facility response procedures, and
mitigation technologies. The RMPs are submitted to LEPCs and the SERC to
facilitate coordination with the local community plan prepared under Title III.
106.505. EMPLOYEE EMERGENCY & FIRE PREVENTION PLANS. 29 CFR 1920.38
This planning requirement, mandated by OSHA, is a general coverage requirement
applicable to all employers that designates actions employers and employees must
take to ensure employee safety from fire and other emergencies. Plans include
emergency escape procedures, route assignments and reporting procedures.
Facilities with less than 10 employees, where the plan may be communicated
orally, are not required to write a plan. Where applicable, these plans should be
incorporated into the RMP.
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106.506. HAZARDOUS WASTE OPERATION AND EMERGENCY RESPONSE
(HAZWOPER). 29 CFR PART 1910.120
In response to Title I of SARA, employers are required to prepare plans covering
emergency response by workers at uncontrolled hazardous waste sites
(1910.120(1)), employees conducting operations at RCRA treatment, storage and
disposal sites (1910.120(p)), and employees involved in emergency response to
hazardous substances releases (1920.120(q)). This latter requirement covers
employees engaged in emergency response no matter where it occurs. The
elements of these response plans include planning and coordination with outside
parties, recognition and prevention measures, evacuation routes and response
procedures. 1910.120(q)(6) also mandates the minimum levels of training
personnel shall have before they can participate in response operations.
106.507. PROCESS SAFETY MANAGEMENT. 29 CFR 1910.119
The Process Safety Management (PSM) standard is intended to protect workers
within a facility from catastrophic releases of specified toxic, flammable and
reactive materials. This standard applies to inside-the-plant environment unlike
other plans that deal with off-site emergency strategies.
107. DISPERSANT and OTHER CHEMICALS USE POLICY;
Guidelines for authorizing the use of dispersant and other chemicals listed on the
NCP Product Schedule occur in NCP Subpart J, Section 300.910 and in the
Region IV RRT Dispersant Use Plan. For the inland zone, the RRT has agreed that
oil dispersants are generally not acceptable for use on water, however limited use
is allowable on land spills that do not threaten surface waters'. The OSC is only
granted authority to use dispersants, surface washing agents, surface collecting
agents, bioremediation agents, or miscellaneous oil spill control agents that are
listed on the NCP Product Schedule, without RRT concurrence, when human lives
are threatened by the oil spill. In non-life threatening situations, the OSC shall
obtain concurrence from USEPA's representative to the RRT and, as appropriate,
the RRT representatives from the State with jurisdiction over the navigable waters
threatened by the release or discharge. Consultation with the Department of
Commerce (DOC) and Department of Interior (DOI) natural resource trustees is also
necessary.
Procedures for use of dispersants on land spills are presented in US EPA Region IV's Guidance on the
Use of Chemical Countermeasures on Roadside Fuel Spills. Copies can be obtained by calling the
USEPA Telephone Duty OSC at (404) 347-4062.
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SECTION 200.
ORGANIZATION AND RESPONSIBILITIES
201. INTRODUCTION;
Federal, State and Local governments have different organizational structures and
response functions during an emergency situation. Contained in this section are
the basic responsibilities for the majority of Federal, State and Local agencies that
either respond to or provide support to response efforts. This includes both RRT
and non-RRT member agencies. The NCP briefly discusses each agency in Section
300.175(b).
202. ORGANIZATIONS:
The National Response System (NRS), as detailed in Section 300.105 of the NCP,
serves to coordinate the efforts of all applicable organizations in a focused
response strategy for the immediate and effective mitigation and cleanup of
discharges of oil and releases of hazardous substances. Presented below are the
individuals and organizations at the Local, State and Federal level, as well as the
private sector, that make up the NRS.
202.1. National Response Team (NRT)
The NRT is primarily a national planning, policy and coordinating body that
provides assistance as requested by an OSC via the RRT during an incident.
However, they do not respond directly to incidents. NRT assistance usually entails
technical advice, access to additional or specialized resources and coordination
with other RRTs. Specific details are found in Section 300.110 of the NCP.
202.2. Regional Response Team (RRT)
The RRT is responsible for regional planning and preparedness activities before
response operations and for providing advice and support to the OSC when
activated during a response. The RRT membership consists of regional
representatives from each Federal agency that participates in the NRT along with
State representation and through the State, Local representation. Federal RRT
member agencies have duties established by Statute or Executive Order which may
apply to Federal response actions following a discharge of oil or a release or a
threat of release of a hazardous substance, pollutant, or contaminant.
A. Standing Regional Response Team
The principal components of the RRT are a standing RRT and incident-specific
RRTs. The Region IV Standing RRT is co-chaired by the Chief, Emergency
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Response and Removal Branch, USEPA Region IV and the Chief, Marine Safety
Division, Seventh Coast Guard District. The standing RRT consists of those
members presented below. State representatives, appointed faty the Governor,
typically come from the State's environmental agency and where possible the
State Emergency Management Agency.
RRT MEMBER AGENCIES
US EPA
US Coast Guard
Department of Interior
Department of Defense
Department of State
Department of Energy
Department of Commerce
Dept. Health & Human Services
Department of Agriculture
Department of Laibor
Department of Justice
Fed. Emergency Management Agency
State Representatives
Department of Transportation
Nuclear Regulatory Commission
General Services Administration
Each member agency should designate one member and at least one alternate
member to the standing RRT. Agencies whose regional subdivisions do not
correspond to the standard Federal regions may designate additional
representatives to the standing RRT to ensure appropriate coverage of the standard
Federal region. Federally recognized Indian Tribal governments are encouraged to
arrange for representation on the RRT. Other interested parties may attend and
observe RRT meetings. Annex 0* contains a roster of the Standing RRT.
To carry out the pre-response preparedness and planning charge of the RRT, a
Management Committee consisting of the Chairs of each of the RRT Committees,
the Co-Chairs and alternate Co-Chairs from USEPA and the USCG and additional
rotating members meets periodically. Specific, continuing RRT issues are
addressed by working committees. Each working committee chair is appointed by
the RRT Co-Chairs.
The role of the standing RRT includes communications and procedures, planning,
coordination, training, evaluation of responses, preparedness, and related matters
on a region-wide basis. These activities include, but are not limited to:
1. Providing technical assistance for preparedness. Conducting and
participating in training and exercises to encourage preparedness activities of
the response community within Region IV. At least one exercise is planned
and conducted annually;
All contact names and phone numbers for organizations discussed in this plan are maintained by
USEPA and may be obtained during an incident response by calling the USEPA Telephone Duty OSC at
<404) 347-4062. The Telephone Duty Officer maintains the right to withhold information from
unauthorized parties.
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2. Discussing, modifying, and adopting procedures to enhance the various
aspects of response coordination between Local, Tribal, State, Regional, and
Federal response efforts;
3. Reviewing and commenting, where practicable, on Local emergency
response plans required by SARA, Title III. Reviews are conducted upon the
request of Local Emergency Planning Committees (LEPC), forwarded to the
RRT by a State Emergency Response Commission (SERC). The standing
RRT may also review and comment on other issues concerning the
preparation or implementation of related response plans;
4. Reviewing, evaluating, and commenting on Regional and Local responses to
discharges or releases, and recommending improvements, as appropriate.
5. Reviewing and updating the RCP;
6. Reviewing OSC actions to ensure that RCPs and OSC contingency plans are
effective;
7. Encouraging State and Local response communities to improve response
preparedness;
8. Conducting advance planning for use of dispersants, surface collecting
agents, in-situ burning, biological additives, or other chemical agents;
9. Meeting on a regular basis to review response actions, address preparedness
and pre-response activities, and consider changes to the RCP. Meeting
locations are rotated among each of the Region IV States;
10. Providing reports on RRT activities to the NRT twice a year, no later than
January 31 and July 31;
11. Integrating, to the extent possible, ongoing planning and preparedness
activities with RRT initiatives, and all RRT agencies. Also, coordinating
planning and preparedness with RRTs in adjacent Regions.
12. Recommending revisions of the NCP to the NRT, based on observations of
response operations;
13. Providing resources for response to major discharges or releases outside the
Region upon request;
14. Evaluating the preparedness of the participating agencies and the
effectiveness of Federal response to discharges and releases; and,
15. Preparing an annual work plan to coordinate emergency response and
preparedness activities.
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B. Incident-specific Regional Response Team
An incident-specific RRT may be activated during a response and consists of
representatives of appropriate Federal, State, and Local governments as required
by the circumstances of the incident. The circumstances under which an incident-
specific RRT will convene are discussed later in this section. An incident-specific
RRT has one Chair - either the Regional Manager for the Federal On-Scene
Coordinator (OSC) or Remedial Project Manager (RPM) responding to the incident
or the USCG District MEP Division Director for the District where the spill occurs.
The role of the incident-specific team is determined by the RRT response to a
specific discharge or release. Participation is relative to the technical nature and
geographic location of the discharge or release. The RRT Chair coordinates with
the RRT membership and the OSC/RPM for the incident, to determine the
appropriate level of RRT member activation. Member agencies and States
participating with the RRT must ensure that designated representatives or
alternates can function as advisory and resource personnel for the OSC/RPM during
incident-specific events.
When activated, members of an incident-specific RRT may be requested to:
1. Provide advice, as requested by the OSC/RPM, and recommend courses of
action for consideration by the OSC/RPM;
2. Monitor and evaluate reports from the OSC/RPM;
3. Advise the OSC/RPM on the duration and extent of a Federal response and
recommend to the OSC/RPM specific response actions;
4. Request other Federal, State, or Local government or private agencies
provide resources, under their existing authorities, to respond to a discharge
or release or to monitor response operations;
5. If circumstances warrant (e.g., substantial movement of the pollution into
the predesignated area of another OSC lead agency), recommend to the RRT
Co-Chairs that an OSC/RPM be changed; and,
6. Ensure continual communications with the National Response Center (NRC)
as significant developments occur.
202.3. Area Committees
Section 4202(a)(4) of the Oil Pollution Act of 1990 requires that Area Committees,
made up of Federal, State and Local officials, be established to develop an Area
Contingency Plan (ACP). The predesignated OSC for the area serves as the Chair
of the Committee and provides general advice and guidance and directs the
Committee's development and maintenance of the ACP. The Area Committee is
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also charged with a responsibility to work with State arid Local officials to enhance
the contingency planning and to assure preplanning of joint response efforts
including procedures for mechanical recovery, dispersant use, shoreline cleanup,
protection of sensitive environmental areas and protection, rescue and
rehabilitation of fisheries and wildlife. In development of the ACP, the committee
must ensure that resources and personnel are adequate to remove or prevent a
worst-case discharge of oil in or near the area covered by the plan. Both USEPA
and the USCG are responsible for overseeing the formation of the Area Committees
and the development of the ACPs for the inland zone and the coastal zones,
respectively. The USCG designated the 48 Captain of the Port Areas as the
coastal zones areas. In the standard Federal Region IV there are nine coastal areas
each with an Area Committee and an ACP. In the inland zone of Region IV, the
standing RRT served as the Area Committee for the initial development of both the
RCP and ACP. Future updates of the plan will include input from Local government
agencies and private parties involved in spill response activities.
OPA AREAS WITHIN FEDERAL REGION IV
Inland Areas fll
USEPA Region IV
Coastal Areas (91
South Florida (MSO Miami)
Northwest Florida (MSO Mobile )
West Florida (MSO Tampa)
Northeast Florida (MSO Jacksonville)
Alabama, Mississippi (MSO Mobile)
Southeastern North Carolina (MSO Wilmington)
Northeastern North Carolina (MSO Hampton Roads)
Georgia, Southeast South Carolina (MSO Savannah)
Northeast South Carolina (MSO Charleston)
202. 4. Sensitive Environmental and Economic Areas
The NCP Sections 300.210(c)(3)(i) and 300.210(c)(4) describe the OPA
requirement for identifying in the ACP those areas of special economic or
environmental importance that might be damaged by a discharge. Annex F
presents general guidelines for distinguishing areas of sensitivity. Specific areas
are being identified in conjunction with State and Local representatives with
relevant expertise. Future updates to the ACP will include more specific
information on sensitive locations and their protection priority status within the
inland area. A general list of agencies and their subject of expertise is presented
on the next page. This information was compiled from Appendix D of 40 CFR 112.
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POTENTIALLY SENSITIVE ENVIRONMENTS
AGENCY
SUBJECT
USEPA
Wetlands {40 CFR 230.3)
Near Coastal Waters Programs
Clean Lakes Program critical areas
National River Reach designated as recreational
NOAA
Critical habitat for endangered/threatened species
Habitat used by endangered/threatened species
Marine Sanctuaries
National Estuaries Program
National Wildlife Refuges
Coast Zone Management Act Designated Areas
DOI
DOI-USFWS
DOI-Nat Park Serv.
DOI-Bur Land Mng.
National Preserves
National Lakeshore Recreation Areas
Scenic or Wild Rivers
Critical habitat for endangered/threatened species
Habitat used by endangered/threatened species
National Wildlife Refuges
Coastal Barrier Resources System
Hatcheries
Waterfowl Management Areas
National Parks
National Seashores Recreational Areas
National Conservation Areas
DOT
National Monuments
USDA
Federal Wilderness Areas
203. RESPONSIBILITIES:
Several of the participating Federal agencies have internal organizations that assist
the agency and the overall response effort. This section describes the individuals
and organizations that make up the framework of the National Response System
and discusses their responsibilities. Some of the organizations involved in
emergency response and removal actions exist as parts of an agency. Others are
created by the response to the situation, function as a unit and disappear at the
conclusion of the event.
203.1. On-Scene Coordinators (OSC)
The OSC is the predesignated Federal official responsible for ensuring immediate
and effective response to a discharge or release. The USCG designates OSCs for
the coastal zone, while the USEPA designates OSCs for the inland zones. The
OSC directs Federal Superfund-financed response efforts and coordinates all other
Federal efforts at the scene of a discharge or release. In the case of a release of a
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hazardous substance on a DOD or DOE facility, the responsible lead agency will
designate the OSC. If an oil discharge occurs on a DOD or DOE facility, the USCG
or USEPA will designate the OSC depending on the location. OSC's general
responsibilities are described below. The OSC's role during a response under this
plan is presented Annex A. USEPA Region IV On-Scene Coordinators are identified
in Annex O of this Plan.
a. Coordinates, directs, and reviews the work of other agencies, responsible
parties, and contractors to ensure compliance with the NCP, RCP and any
other documents such as decision documents, consent decrees,
administrative orders, and/or lead agency-approved plans.
b. Notifies the appropriate State and Federal agencies of any reported discharges
or potential discharges. Notification responsibilities are discussed in Annex B.
c. Determines whether proper response actions have been initiated. If the party
responsible for the release or spill does not act promptly in accordance with
directions of the OSC or does not take appropriate actions, or if the party is
unknown, the OSC shall respond in accordance with provisions of the NCP,
RCP, ACP and agency guidance.
d. Collects pertinent information on the discharge or release (i.e., its source and
cause; responsible parties; nature, amount, location, direction, and time of
discharge; pathways to human and environmental exposure; potential impact
on and protection priorities for human health, welfare, and safety, and the
environment; possible impact on natural resources and property; and
estimated response costs).
e. Coordinates efforts with other Federal, State, and Local agencies. Consults
with and informs RRT members of reported discharges and releases through
Pollution Reports (POLREPs). See Annex B for information on how to write
POLREPs.
f. Consults with the appropriate Regional or District office regarding situations
potentially requiring temporary or permanent relocation. In the event of a
declared Federal disaster, coordinates with the FEMA Federal Coordinating
Officer (FCO) as appropriate.
g. Implements appropriate community relations activities as presented in Annex I
of this plan.
h. Appropriately addresses worker health and safety issues prior to and during a
response operation. Health and safety issues are discussed in Annex G.
i. Coordinates with Scientific Advisors from various agencies, as the OSC
deems necessary, regarding possible public health risks and environmental
sensitivity. Refer to Annexes J and F for more information.
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203.2. Remedial Project Managers (RPM)
The RPM is assigned responsibility for remedial and other response actions taken at
sites on the National Priorities List (NPL), and for sites not on the NPL but under
the jurisdiction, custody, or control of a Federal agency. It is not the intent of this
plan to repeat the remedial program found in the NCP, rather, this Plan is an
emergency response and removal document. For more specific information
concerning RPMs refer to Section 300.120 of the NCP. The Staffing Plan of the
Waste Management Division lists USEPA Region IV RPMs.
203.3. Federal RRT Member Agencies
The responsibilities of the Federal agencies listed in this section have been
established by statute, executive order, or Presidential directive. The
responsibilities listed may apply to Federal actions in the prevention of, or following
the discharge of oil or release of a hazardous substance, pollutant, or contaminant.
Additionally, some of these agencies also have duties relating to the restoration,
rehabilitation, replacement, or acquisition of equivalent natural resources injured or
lost as a result of such discharge or release.
During preparedness planning or in an actual response, these federal agencies,
consistent with their legal authorities and capabilities, may be called upon to
provide assistance in their respective areas of expertise, as indicated in this
section. To be responsive to the requirements of this plan, all RRT member
agencies should plan for emergencies and develop procedures for addressing oil
discharges and releases of hazardous substances, pollutants, or contaminants from
vessels and facilities under their jurisdiction, custody, or control. All Federal
Region IV RRT member agencies should be prepared to provide OSCs/RPMs with
assistance from their respective agencies commensurate with responsibilities,
resources, and capabilities.
Responsibilities common to all RRT member agencies include:
a. Providing representatives to the RRT and assisting the RRT in the formulation
of the RCP and providing assistance to designated OSCs in the development
of Area Contingency Plans;
b. Informing the RRT of changes in the availability of their response resources;
and,
c. Reporting discharges and releases from facilities or vessels under their
jurisdiction or control.
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RRT MEMBERS' RESPONSIBILITIES and FUNCTIONS
203.301. UNITED STATES COAST GUARD (USCGl
The USCG is an agency of the Department of Transportation. The Coast Guard
provides the Co-Chair for the standing RRT and predesignated OSCs for the coastal
zone. The USCG also supplies expertise in the domestic/international fields of port
safety and security, marine law enforcement, navigation, and construction, and the
manning, operation, and safety of vessels and marine facilities. The USCG
maintains continuously manned facilities that are capable of command, control,
and surveillance for oil or hazardous substances releases occurring in the coastal
zone and on the major inland rivers of the region and may provide these services to
the OSC. The USCG also provides response support through the Strike Teams and
the National Strike Force Coordination Center (NSFCC).
203.302. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY (USEPA)
The USEPA provides the Co-Chair of the Region IV standing RRT and provides
OSCs for the inland zone and for all other areas for which an ACP is required under
section 311 (j) of the CWA. USEPA is responsible for providing expertise regarding
environmental effects of pollution releases and environmental pollution control
techniques. USEPA will also advise the RRT and the OSC of the degree of hazard
a particular release poses to the public health and safety, coordinate damage
assessment and will generally provide the Scientific Support Coordinator for the
inland zone.
203.303. DEPARTMENT OF AGRICULTURE (USDAI
The USDA has the capability to measure, evaluate and monitor situations where
natural resources have been impacted by fire, insects and disease, floods,
hazardous substances and other natural or man-caused emergencies. USDA is
represented on the RRT through the United States Forest Service (USFS), the
designated member of the RRT. The USFS is responsible for protection and
management of national forests and grasslands. The USFS maintains specially
trained incident management teams and also has capabilities to provide emergency
communications systems, specialized aircraft, and human support facilities for
large groups of people. In addition, the USDA is among those agencies designated
by the NCP as a Federal Trustee for Natural Resources.
Other USDA agencies include:
The Food and Nutrition Service (FNS), through the Food Distribution Program,
provides food as emergency assistance to disaster victims. In appropriate
emergency situations, FNS will authorize State agencies to issue food stamps
based on emergency procedure.
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Food Safety and Inspection Service (FSIS) tests meat and poultry products for
the presence of violative drugs, chemical residues, and other adulterants.
Agricultural Stabilization and Conservation Service (ASCS) in cooperation with
the Forest Service, Soil Conservation Service, and Army Corps of Engineers, is
responsible for emergency plans and preparedness programs for food
processing, storage, and distribution through the wholesale level.
Animal and Plant Health Inspection Service (APHIS) provides expertise on plant
and animal diseases and health.
National Agricultural Statistics Service (NASS) serves as a source of data on
crops, livestock, poultry, dairy products, and labor. State Statistical Offices
collect and publish Local information on these topics.
203.304. DEPARTMENT OF COMMERCE (DOC)
The DOC, through NOAA, provides support to the RRT and the OSC in areas of
scientific support for response and contingency planning in coastal and marine
areas, including assessment of the hazards that may be involved, predictions of
movement and dispersion of oil and hazardous substances and cleanup and
mitigation methods. DOC, through NOAA, has three roles within Region IV:
1. Provides Scientific Support Coordinator (SSC), in accordance with the NCP;
2. Federal Trustee for Natural Resources, in accordance with the NCP.
3. RRT member. Can provide scientific expertise on living marine resources for
which it is responsible,- provide current and predicted meteorologic,
hydrologic, ice, and oceanographic conditions,* provide charts and maps; and
can provide communication services to the general public, various levels of
government, and the media via its weather wire and weather radio system.
203.305. DEPARTMENT OF DEFENSE (POD)
The DOD can take all actions necessary to respond to releases of hazardous
substances where either the release is on, or the sole source of the release is from
any facility or vessel under the jurisdiction, custody or control of DOD. In these
situations, DOD will provide the OSC. DOD also serves as a Federal Trustee for
Natural Resources.
The United States Army Corps of Engineers (USACE) provides design services,
performs construction services, provides potable water when a source becomes
contaminated, conducts modelling activities, manages locks and dams and
provides navigation controls for major rivers. The USACE also has an Interagency
Agreement with USEPA to conduct community evacuation services when
necessary.
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The US Navy is the federal agency most knowledgeable and experienced in ship
salvage, shipboard damage control and diving. The USN has an extensive array of
specialized equipment and personnel available for use in these areas as well as
specialized containment, collection and removal equipment specifically designed for
salvage-related and open-sea pollution incidents.
203.306. DEPARTMENT OF ENERGY (DOEI
The DOE provides the designated OSC/RPM for responses to releases on or from
any facility or vessel under its jurisdiction. Under the Federal Radiological
Emergency Response Plan (FRERP), DOE provides advice and assistance
radiological assistance to the RRT and OSCs for emergency actions essential to the
control of radiological hazards. DOE also administers, implements, and coordinates
the Federal Radiological Monitoring and Assessment Plan (FRMAP) to provide a
framework for coordinating the radiological monitoring and assessment activities of
Federal agencies during radiological emergencies. In addition, DOE is among those
agencies designated by the NCP as a Federal Trustee for Natural Resources.
203.307. FEDERAL EMERGENCY MANAGEMENT AGENCY (FEMA1
FEMA provides guidance, policy and program advice and technical assistance in
hazardous materials, chemical and radiological emergency preparedness activities.
FEMA monitors and provides technical assistance regarding public sector
emergency response planning, training and exercising for incidents involving
hazardous materials. When the President declares a disaster or emergency, FEMA
coordinates Federal assistance, through the activation of the Federal Response
Plan. Coordination with the Federal Coordinating Officer (FCO) in a situation where
both the Regional Contingency Plan and the Regional Response Plan authorities are
active takes place through the Emergency Support Function #10 which is included
as an Annex to this plan.
203.308. GENERAL SERVICES ADMINISTRATION (GSAI
The GSA, upon request, provides logistical and telecommunications support to
Federal RRT agencies. The support includes, but is not limited to, provision of
space, transportation, supplies, telecommunications, and procurement-related
services. GSA personnel may be located at the scene of the oil or hazardous
material release, or at their regular duty stations, depending on the specific
requirements of the OSC or the emergency situation. Expenses incurred by GSA in
providing requested assistance to other agencies must be reimbursed.
203.309. DEPARTMENT OF HEALTH AND HUMAN SERVICES (HHS)
HHS is responsible for providing expertise and advice on public health and worker
safety issues associated with releases or threatened releases of hazardous
substances; for all health studies and surveys conducted under CERCLA; and
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for providing and maintaining information concerning the health effects of toxic
substances.
The principal HHS response conies from the United States Public Health Service
(USPHS). This response is coordinated from the USPHS regional office. The
primary response to a hazardous materials emergency comes from the Agency for
Toxic Substances and Disease Registry (ATSDR) and the Centers for Disease
Control (CDC). Both ATSDR and CDC maintain a 24 hour emergency response
capability and through scientific and technical personnel provide technical
assistance to the lead federal agency and State and Local response agencies on
human health threat assessment and analysts and exposure prevention and
mitigation. Such assistance is used for situations requiring evacuation of affected
areas, human exposure to hazardous materials and technical advice on mitigation
and prevention. CDC takes the lead in petroleum discharges regulated under the
CWA and OPA while ATSDR takes the lead for chemical releases under CERCLA.
203.310. DEPARTMENT OF THE INTERIOR (DOH
DOI will provide, through its Regional Environmental Officer (REO), technical
expertise to the OSC and the RRT with respect to land, fish, wildlife and other
resources for which it is responsible. The REO is the designated DOI member to the
RRT and can provide information concerning the lands and resources specifically
under DOI jurisdiction, as well as offer technical expertise related to geology,
hydrology, minerals, fish and wildlife, cultural resources, and recreation resources.
Under Executive Order 12580, DOI is among those agencies designated by the
N CP as a Federal Trustee for Natural Resources.
DOI has direct jurisdiction for the protection of resources on its own lands, as well
as trustee responsibilities for certain natural resources, regardless of location. The
DOI natural resource trusteeship that extends beyond DOI site boundaries includes
migratory birds, anadromous fish, and endangered or threatened species and their
critical habitat.
Within the Department, individual bureaus have specific responsibilities and
capabilities which are listed below. Each bureau may be contacted through the
DOI Regional Environmental Officer.
The United States Fish and Wildlife Service (USFWS) provides expertise on
migratory birds, endangered and threatened species, and wildlife habitat, and
can advise on fish and wildlife protection methods,endangered and threatened
species, waters and wetlands and effects on natural resources. The agency can
provide information on national wildlife refuges, national fish hatcheries
managed by USFWS, dispersion or capture of birds, and coordination of wildlife
rehabilitation activities at spill sites. USFWS issues migratory bird rehabilitation
permits to qualified individuals and/or organizations that may be available to
assist in rehabilitation operations related to oil spill incidents. The National Park
Service (NPS) provides general biological, natural and cultural resource managers
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to evaluate, measure, monitor and contain threats to park land and resources;
historic, archeological, architectural, and recreational resources and sites on the
National Register of Historic Places. The NPS can provide information on units
of the national park system, including national parks, lake shores, monuments,
national historic sites, rivers, and recreation areas.
The United States Geological Survey (USGS) provides advice and information
concerning geohydroiogic, geologic and geochemical data, and ground and
surface water data, as well as maps. USGS maintains stream flow gauges in
every State and can provide historical stream flow information, assist in
predicting the time/travel/trajectory of spills, and can collect and analyze surface
and groundwater samples.
The Bureau of Indian Affairs (BIA) coordinates activities affecting Indian Tribal
lands, and provides assistance in identifying Indian Tribal government officials.
The Bureau of Land Management (BLM) has expertise in minerals, soils,
vegetation, archeology, and wildlife habitat.
The Bureau of Mines (BOM) assists in the analysis and identification of inorganic
hazardous substances, and has technical expertise in metals and metallurgy
relevant to site cleanup. BOM has expertise in minerals (occurrence, production,
and research), mining, mining techniques, and metallurgical practices.
The Bureau of Reclamation (BOR) has expertise in water management, flow
control, and water quality improvement. BOR can perform well drilling and
subsurface hyrogeological investigation and analysis.
203.311. DEPARTMENT OF JUSTICE (DOJt
The DOJ members of the RRT serve as representatives for their agency and not as
legal counsel to the RRT or its member agencies. Although the DOJ representative
to the RRT is not a substitute for a member agency's in-house counsel, the DOJ
representative will be able to offer the advice, views, and expertise of the
Department with respect to the RRT's long-term planning and incident-specific
functions.
The Department's primary role is to serve as litigation counsel for the Federal
government and as legal counsel on enforcement and inter-agency matters. As a
consequence, DOJ participation in RRT activities will ordinarily focus on litigation
concerns of response activities and inter-agency coordination. In this capacity, the
role of the DOJ representative might include: general legal advice; review and
comment on regional planning and procedural documents; and incident-specific
assistance, including assigning staff attorneys when the incident may result in
litigation or raise difficult issues of interagency coordination.
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203.312. DEPARTMENT OF LABOR (POL1
DOL, through the Occupational Safety and Health Administration (OSHA),
conducts safety and health inspections of hazardous waste sites to ensure
employees are being protected and to determine compliance with its regulations.
Through OSHA, DOL will also provide the OSC/RPM with advice, guidance, and
assistance regarding hazards to persons involved in response activities and in the
precautions necessary to prevent harm to their health and safety.
203.313. THE DEPARTMENT OF STATE (DOS)
The DOS leads in developing joint international contingency plans. It also provides
assistance in coordination when a pollution release crosses international boundaries
or involves foreign flag vessels. DOS coordinates requests for assistance from the
Government of Canada and United States proposals for conducting research at
incidents that occur in Canadian waters.
203.314. DEPARTMENT OF TRANSPORTATION (DOT!
DOT provides expertise regarding transportation of oil or hazardous materials by all
modes of transportation. Through the Research and Special Programs
Administration, DOT offers expertise in the requirements for packaging, handling
and transporting hazardous materials.
The Office of Pipeline Safety oversees the operation of interstate pipelines and is
responsible for the approval of Facility Response Plans for pipelines.
203.315. NUCLEAR REGULATORY COMMISSION (NucReoComm)
The NucRegComm will respond, as appropriate, to releases of radioactive materials
by its licensees to monitor the action of those licensees and assure that the public
health and environment are protected and adequate recovery operations are
instituted. The NucRegComm will also provide advice to the OSC and the RRT
when assistance is required in identifying the source and character of other
hazardous substance releases where the NucRegComm has licensing authority for
activities utilizing radioactive materials.
203.4. State Responsibilities
Because of the diversity of incidents involving oil and hazardous substances and
the potential impact to public safety as well as to public health, welfare and the
environment, the Governor of each State is requested to designate representatives
to the RRT from both the agency responsible for response to environmental
emergencies and the State emergency management agency. Each State
representative may participate fully in all activities of the RRT and are expected to
coordinate with the State Emergency Response Commissions (SERC) in their
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respective States in order to communicate and coordinate preparedness and
pre-response planning activities between the State and the RRT. State and Local
government agencies are encouraged to coordinate the State contingency planning
efforts for response to hazardous material events with this plan and with
requirements of SARA Title ill and OPA.
Section 300.180 of the NCP describes State and Local participation in a response.
Ordinarily, State and Local public safety organizations are the first government
representatives at the scene of a discharge or release. As first responders they are
expected to initiate public safety measures, consistent with containment and
cleanup requirements as stated in the NCP, that protect the public health and
welfare. They are also responsible for directing evacuations pursuant to existing
State or Local procedures. The State OSC at a spill works closely with the
Incident OSC as an advisor on State issues.
203.5. Local Operations
As provided by Sections 301 and 303 of Superfund Amendments and
Reauthorization Act (SARA), the SERC of each State, appointed by the Governor,
is to designate emergency planning districts, appoint Local emergency planning
committees (LEPCs), supervise and coordinate their activities, and review Local
emergency response plans. The SERC is also to establish procedures for receiving
and processing requests from the public for information generated by Title ill
reporting requirements and to designated an official to serve as coordinator for
information. The Region IV RRT places a great deal of emphasis on States
assisting local communities in the development of local contingency plans.
Local governments, because of their proximity to the event are usually the first
responders on the scene. They will deploy response resources within their
capability, usually in coordination with the State. Their primary concern is with the
protection of the population at risk. This includes activities such as alerts and
warnings, notifications, evacuations or in-place sheltering, law enforcement,
emergency medical response, rendering continuing assistance to the community to
include provision of shelter and mass care and other functions relating to the
protection of the public. When protection of the public is at issue and a unified
command system is in place, the local Incident Commander usually assumes a
unified command role. During responses to oil spills, local agencies may not be
involved as part of the unified command, but provide agency representatives who
interface with the command structure.
203.6. Owners/Operators
Section 4202(a)(5) of OPA requires owners and operators of tanks, vessels or
facilities, as described in Section 4240(a)(5)(B), to prepare and submit to USEPA
for review, a Facility Response Plan (FRP). The plans shall describe in detail the
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procedures for preventing or responding to a worst-case discharge from the tank
vessel or facility.
In the event of a release or threat of a release, the owner(s) and/or operator(s) are
responsible for conducting notification procedures response in accordance with the
NCP.
203.7. Private, Non-governmental Organizations
Within Federal Region IV, there are a number of private and non-governmental
groups that can provide assistance during a response. Industries, co-operatives,
academic groups, and others are encouraged to provide assistance and resources.
Often the most significant contributions are their technical expertise and response
equipment. Several groups are discussed below:
203.701. ENVIRONMENTAL ORGANIZATIONS - To be developed
203.702. COOPERATIVES - To be developed
203.703. VOLUNTEERS - To be developed
203.8. Natural Resource Trustees
Section 101 of CERCLA and Subpart G of the NCP designate, on behalf of the
President, those federal officials who will act as Natural Resource Trustees and
sets forth their responsibilities. State trustees and Indian tribe chairmen are
appointed to represent their respective State's or Indian tribe's natural resources.
For this plan, trustees' responsibilities are consistent with those presented in
Section 300.615 of the NCP. It is the responsibility of the Incident OSC, either
directly or through the RRT, to promptly notify the appropriate trustees if natural
resources are or may be damaged by the discharge.
In Region IV, the Federal Trustees are represented by the following RRT members:
a. Department of the Interior Representative: for national parks, national
monuments, national historic sites, national recreation areas, wild and scenic
rivers, national wildlife refuges, national fish hatcheries, waterfowl
production areas, migratory birds and endangered species, public lands,
lands and waters managed or protected in association with Reclamation
dams, reservoirs and water conveyance systems, Federally-owned minerals,
Indian Reservations, and other lands or natural resources held in trust for an
Indian Tribe;
b. Department of Commerce's NOAA Representative: The Secretary of
Commerce shall act as trustee for natural resources managed or controlled
by DOC or by other federal agencies and that are found in or under waters
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navigable by deep draft vessels, in or under or using tidally influenced
waters or waters of the contiguous zone, the exclusive economic zone and
the outer continental shelf.
c. Department of Agriculture's Forest Service Representative; for national
forests and grasslands
d. Department of Defense:
1 • POD USArmv Representative: for military lands
2. USACE Representative: for Corps of Engineers Project Lands
e. Department of Energy: The Natural Resource Trustee for DOE Savannah
River is the Director, Environmental and Laboratory Programs Division.
f. States: are designated by the Governor of each State. Names and phone
numbers are maintained by USEPA Region IV.
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SECTION 300. CONCEPT OF OPERATIONS
301. GENERAL
The response to an incident involving oil or hazardous substances that requires
federal action and assistance will be made by a predesignated Federal OSC, The
role and responsibility of the OSC is to direct and coordinate Federal resources in
accordance with the NCP and assist in managing the technical/removal aspects of
an oil or hazardous substance incident that presents a public health or
environmental threat. When hazardous substances are involved. Federal OSCs
normally do not assume command of specific local emergency management
functions from local commanders unless specifically requested to do so and feel
capable of assuming that role.
Response actions during incidents involving oil or hazardous materials often are
directed toward two separate but related threats or impacts. Simply stated, these
are:
1. Public Safety: A response to manage the emergency conditions
caused by the release of the material which directly threatens the lives
of people at risk, i.e., threats to public safety and property. This
response is usually made by local first responders to the extent of
their capability.
2. Public Health and Environmental: A parallel response to "manage"
(contain, cleanup, remove dispose etc.) the released or discharged
product.
For incidents involving protection of the public, via fires, explosions, minor releases
of toxic airborne clouds or other similar incidents, there is usually little or no
Federal involvement beyond communicating risks imposed by the released material.
Local public safety (fire, law enforcement, emergency medical) agencies and
officials are the first responders regardless of the magnitude of the incident. They
may establish an Incident Command System and direct appropriate response
actions. When incidents occur on public property, such as a transportation
incident on a public highway or railway, the party responsible for the incident is
required to cooperate with and aid the local responders but typically does not
direct or implement fire fighting, evacuations or other first responses to the
incident.
The responsible party (spiller), state environmental agencies and the OSC assume a
more proactive role when the situation requires a response to manage public health
and environmental protection. Local response personnel continue to manage public
safety issues and provide support and assistance to the OSC within their
capabilities. Thus, a discharge of oil or a release of a hazardous substance(s) may
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pose a threat or impact to public safety, public health and welfare, property or the
environment. In an incident during which this plan is activated and a federal OSC
response is required, a multi-organizational response network may be deployed to
meet the varied demands of the situation. Included in this network are resources of
the Federal, State and local governments, the responsible party, response
contractors and in some cases volunteer groups and individuals.
In the first response situation, local response forces are normally the first on scene
and undertake response actions in accordance with local plans and capabilities. It
is likely that the first response forces will establish an Incident Command System.
The response mechanisms in this plan are designed to incorporate into and
function within a comprehensive command and control structure. This unified
command system expands the initial ICS and facilitates a coordinated response
effort which takes into account the Federal, State, local and responsible party
responsibilities, concerns and interests when implementing the response strategy.
See Annex A for details on the Incident Command/Unified Command System.
The role of State agencies in a public safety response during the early stages of an
incident is to provide advice and assistance to local responders. During major
incidents, state and Federal responders will be available to provide additional
assistance to the local incident commander by providing technical assistance such
as air, water and soil sampling, analysis of chemicals, providing specialized
resources and equipment from agency or contractor sources and providing detailed
advice or other assistance.
Region IV maintains a sufficient quantity of response vehicles, monitoring devices
and safety equipment to allow for safe and effective response to most incidents.
The agency does not maintain an ability to conduct removal operations utilizing its
own personnel and equipment. When applicable, the OSC possesses the authority
to utilize a commercial clean-up contractor to perform removal operations. The
OSC's investigate the incident as well as direct Federal fund financed removal
operations to minimize the impact on the public and environment.
The first Federal official affiliated with a RRT agency to arrive at the scene of a
discharge or release should coordinate activities under the NCP, RCP, and agency
guidance until the predesignated OSC is available. That Federal official should
consult directly with the predesignated OSC regarding any necessary initial actions.
Fund-financed operations must be authorized by the OSC prior to implementation.
302. MULTIREGIONAL RESPONSES
If a discharge or release moves from the area covered by one RCP or OSC/RPM
contingency plan into another area, the authority for response actions should
likewise shift. If a discharge or release affects areas covered by two or more
RCPs, the response mechanisms of both may be affected. In this case, response
actions of all regions concerned shall be fully coordinated as detailed in the RCPs.
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There shall be only one OSC and/or RPM at any time during the course of a
specific response operation. Should a discharge or release affect two or more
areas, USEPA, USCG, the Department of Defense, Department of Energy, or other
lead agency, as appropriate, shall give prime consideration to the area vulnerable to
the greatest threat, in determining which agency should provide the OSC and/or
RPM. The RRT shall designate the OSC and/or RPM if the RRT member agencies
who have response authority within the affected area are unable to agree on the
designation. The NRT shall designate the OSC and/or RPM If members of one RRT
or two adjacent RRTs are unable to agree on the designation.
Where USCG has initially provided the OSC for response to releases from
hazardous waste management facilities located in the coastal zone, responsibility
for response action shall shift to USEPA or another Federal agency, as appropriate.
The OSC/RPM shall be provided by the Region within which the release occurs, or
according to preestablished protocols.
303. REMOVAL ACTIONS
The NCP Section 300.415 states that at any release, if the quantity of
contamination in the environment is great enough to threaten or damage public
health or the environment, the lead agency can take any appropriate actions to
remove or minimize the release or threat of release. This also includes actions to
the restore the environment to pre-incident conditions. Often these removal
actions take place somewhat later than the public safety protection measures.
Whether conducted by the responsible party, the State or the Federal government,
removal actions can go on for a much longer period of time. Classical removal
actions, such as those taken by a Federal OSC can include the placement of
containment and recovery devices, sampling of soil, air, run-off and water bodies,
excavating soil, performing hydrogeological investigations and other similar
"technical" activities.
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SECTION 400. ADMINISTRATION AND LOGISTICS
401. REPORTING
A. Pollution Reports (POLREPs): are prepared by the designated OSC for each
release or potential release in which an on-scene response occurs. The OSC
submits POLREP's to the RRC as significant events occur. For medium and major
releases, a POLREP will be submitted on a regular or periodic basis until, in the
judgement of the OSC, the response operation and impact of the discharge or
release have stabilized. B. OSC Reports: OSCs shall submit OSC reports to the
RRT or NRT only if requested as provided by Sec. 300.165 of the NCP.
For information on reporting requirements and procedures during a response refer
to Annex B further in this plan.
402. RECORDKEEPING
Documentation to support all actions taken under the various response authorities
must be sufficient to support full cost recovery for resources utilized. These
records shall identify the source and circumstances of the incident, the responsible
party or parties and impacts and potential impacts to public health and welfare and
the environment. Refer to Annexes A and B for details.
403. FUNDING
The person (s) responsible for discharges or releases are liable for the cost of the
cleanup as mentioned in Sections 300.335 and Subpart E of the NCP. The OSC
shall attempt to have the party responsible for the discharge or release voluntarily
assume responsibility for containment, removal and disposal and restoration
operations. If the OSC determines that the responsible party is not responding
properly, the OSC shall take appropriate actions established by OPA, CWA or
CERCLA. The OSC shall notify the responsible party of the potential liability for
federal response costs incurred by the OSC pursuant to the appropriate authorities.
See Annex H for details on Funding and Contracting. State and Local governments
must obtain an appropriate contract or cooperative agreement before they are
authorized to take actions involving expenditures of the Oil Spill Liability Trust Fund
(OSLTF) or CERCLA funds. Procedures for accessing the OSLTF are described in
33 CFR Part 136.
404. (AGs AND MOUs
To facilitate response operations, the USEPA and several other Federal agencies
have entered in Interagency Agreements (lAGs) or Memorandums of Understanding
(MOUs). Details on specific I AGs and MOUs are presented Annex N of this plan.
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SECTION 500. DIRECTION AND CONTROL
The Incident OSC, consistent with Sections 300.120, 300.125, and 300.305 of
the NCP, shall direct response efforts under the ACP and coordinate all other
efforts at the scene of a discharge or release. OSCs for the inland zone of are
appointed by the USEPA Regional Administrator. Incident OSCs for the inland zone
are assigned by the USEPA ERRB Branch Chief or a Section Chief during the initial
phase of the response. EPA Region IV On-Scene Coordinators are identified in
Annex 0 of this Plan.
The first Federal official affiliated with a RRT member agency to arrive at the scene
of a discharge or release should coordinate activities under the RCP and is
authorized to initiate, in consultation with the responding Incident OSC, any
necessary actions normally carried out by the Incident OSC until the arrival of the
Incident OSC. Ultimate authority in a response operation with respect to all
actions and issues involved with the protection of public health and the
environment belongs to the Incident OSC. If no system is in place upon arrival on-
scene, the Incident OSC will establish a Unified Command System which will
include the Incident Commander, the State Incident OSC, a Local representative
and the Responsible Party's Incident Manager.
The Regional Response Center, located within the USEPA Regional Office in
Atlanta is the coordination center for all inland zone responses conducted by an
USEPA designated Incident OSC. Coastal zone responses will be controlled and
coordinated through the provisions of the appropriate Area Contingency Plan.
Coastal spills or open ocean spills covering two or more COTP zones will be
coordinated at the District Operations Center.
NCP RULES and REGULATIONS
§ 300.120 On-scene Coordinators and remedial project managers: general responsibilities, (a): The OSC/RPM
directs response efforts and coordinates all other efforts at the scene of a discharge or release.
§ 300.125 Notification and communications.
§ 300.305 Phase ll-Preliminary assessment and Initiation of action. (d)(1): In carrying out a response under this
section, the OSC may: (i) Remove or arrange for the removal of a discharge, and mitigate or prevent a substantial
threat of a discharge, at any time; (ii) Direct or monitor all federal, state, and private actions to remove a discharge;
and (iii) Remove and, if necessary, destroy a vessel discharging, or threatening to discharge, by whatever means are
available.
(d)(2): If the discharge results in a substantial threat to the public health or welfare of the United States {including
but not limited to fish, shellfish, wildlife, other natural resources, and the public and private beaches and shorelines
of the United States), the OSC must direct all response efforts, as provided in S 300.322
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ANNEX A;
SPILL RESPONSE ORGANIZATION AND COMMAND
PURPOSE and SCOPE: Every spill, although unique in location, size, and
surrounding environment, requires an organized response performed by qualified
personnel. To minimize confusion during a response and facilitate coordination
between responding parties, a unified command system (UCS) has been adopted
for use for a response under this plan. This Annex presents the command
structure for organizing people and resources to respond to a discharge of oil
within the Region IV inland area.
PROCEDURES: A brief description of a spill scenario is presented in the
beginning of the Annex. This is to familiarize the reader with the possible
conditions of a spill and to give a sense of where the various command centers
and resources are located. The remainder of the Annex is a flow chart of the UCS.
The entire chart is presented showing all the various functions and their
relationship to the Incident On-Scene Coordinator. The chart is further divided into
specific responsibilities which serve as a checklist or reminder of actions to
consider for performance, if applicable to the particular incident.
A SPILL SCENARIO: During a spill event, particularly a worst-case spill, the
EPA Region IV Emergency Response and Removal Branch's Telephone Duty OSC is
notified by either the discharger, the State, or the National Response Center. The
Telephone Duty OSC, after collecting as much information as possible, determines
if the discharge poses a substantial threat to public health or welfare. If it is
determined that there is a significant or suspected significant threat, then the
Telephone Duty OSC sends the Incident OSC to the spill site along with any
necessary resources. For specific information on notification procedures refer to
Annex B.
Once at the site, the Incident OSC evaluates the effectiveness of any activities
being conducted either to contain the release, prevent its spread into the
environment, or to collect material already spilled. Given a typical scenario, the
discharger conducts the necessary response activities. The Incident OSC oversees
or directs the discharger to ensure that the contractor conducts work according to
the appropriate regulations and rules of safe practice.
Under EPA Region IV's worst-case scenario, the party(ies) responsible for the
discharge are unable or unwilling to take any response measures. Given such
conditions, even small spills demand a very structured organization and
coordination system. Typically, the magnitude of the release is not obvious in the
first few hours. As the impact becomes more severe, the Incident OSC's support
requirements escalate requiring additional personnel and equipment to be sent to
the scene. Command centers need to be established to handle these increases.
A-1 (update JAN 1995)
0046
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The Mobile Command Post serves as the Forward Command Post for responders in
the field while the Incident OSC relocates to an Incident Operations Center (IOC)
away from site activities. This allows the Incident OSC to coordinate between the
RRC in Atlanta, confer with the RRT, and direct all field activities without
becoming overwhelmed by minor problems.
Since no one OSC can handle all the demands of a response. Cleanup Teams and
Advance Teams, headed by OSCs, are sent to the field. Cleanup Teams lead or
oversee the containment, recovery and cleanup efforts going on in areas that have
been impacted by the spilled material. Advance teams go downstream or into
areas that have not been impacted yet to determine resource needs and take
proper preventative measures. All field teams report back to and receive
concurrence from the Incident OSC regarding any activities.
UNIFIED COMMAND: The UCS establishes an organized structure enabling
government agencies, industry and the responsible party to coordinate activities
during any type of spill response. Developed by fire fighters to promote teamwork
and coordination, the UCS is the lowest level of the National Response System. It
is designed to parallel any command organization of a private or responsible party.
Figure A-1 of this Annex presents the UCS structure to be used during a response
under this plan.
The UCS, which is centered around the Incident OSC position during oil spill
responses, should be used by all parties (government and private) as a first
response guide to immediately establish their role and assigned duties. Each
government agency or private party shall participate in the UCS at the appropriate
decision making level (or the position designated by the Incident OSC) while
retaining their own organizational identity, direct control of personnel and resource
tasking. Depending upon the scenario, a separate individual in each position or one
individual may fill several positions. As with any command structure, all activities
conducted under a particular UCS function shall be coordinated through the
Incident OSC. Utilization of this structure will facilitate the most efficient use of all
available resources.
FOR ADDITIONAL INFORMATION:
Communication
Incident Command Center
Mobile Command Post
Notification
Response Evaluation
Response Strategies
Telephone Duty OSC
Annex 8
Annex B
Annex B
Annex B
Annex C
Annex C
Annex B
A-2 (update JAN 1995)
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FIGURE A-1. SPILL RESPONSE UNIFIED COMMAND STRUCTURE (UCS): This flow chart shows the functions and their
relationship to the Incident OSC. This shopping list of assistance resources allows the OSC to expand response capabilities directly
proportional to the demands of the incident, or as the threat becomes more complicated. Government agencies and private parties shall
participate at the appropriate decision making level or at the level designated by the Incident OSC.
PUT CHART ON THIS PAGE
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ORGANIZATIONAL CHART
DISCHARGER
STATE
LOCAL
NATURAL
INCIDENT
REGIONAL
RESPONSE
TEAM
MANAGEMENT SUPPORT j l
/ i r
REGIONAL
RESPONSE
CENTER
REGIONAL
INCIDENT
COORDINATION
TEAM
OSC STAFF
• DEPUTY INCIDENT OSC
- PUBLIC AFFAIRS LIASON
•SAFETY COORDINATOR
- DOCUMENTATION COORDINATOR
FINANCE
• FINANCE OFFICER
¦ ENFORCEMENT COORDINATOR
PROCUREMENT COORDINATOR
CLAIMS COORDINATOR
- COST TRACKER
LOGISTICS
-LOGISTICS OFFICER
- RESOURCE COORDINATOR
- PERSONNEL/VOLUNTEER COORD,
¦ TRANSPORTATION COORD,
- TRAINING COORD
- COMMUNICATIONS COORD.
¦SECURITY COORD.
sa
PLANNING
- PLANNING OFFICER
- ADVANCE TEAMS COORD.
* Advance Teams
- HOW CLEAN IS CLEAN TEAM
- DISPOSAL COORD.
• SCIENTIFIC SUPPORT COORD.
* Risk Assessment
* Sensitive Environments
OPERATIONS
• OPERATIONS OFFICER
• CLEAN-UP TEAM COORD.
* Clean-Up Teams
- WILDLIFE RESCUE COORD.
C5
NATURAL
RESOURCE
DAMAGE
ASSESSMENT
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1 INCIDENT OSC \
SCOPE: The Incident OSC is the predesignated Federal official responsible for
ensuring immediate and effective response to a discharge. They are the prime
coordinator and manager for all operations, including the development of the overall
and daily strategic objectives. As part of the UCS, the Incident OSC approves the
ordering and release of resources, supervises and monitors all functions, coordinates
exchange of information and participates in media releases.
The Incident OSC shall designate individuals from Federal, State, local and private
groups, as necessary, to fill the designated functions under the Command System.
Depending upon the spill situation, one individual may fill several functions or one
function may require an entire support staff. As with any command structure, all
activities conducted under a particular function shall be coordinated through the
Incident OSC. Although the Incident OSC has authority to make decisions,
recommendations and input from other members of the response structure should be
consulted.
INCIDENT OSCs AUTHORITIES
National Contingency Plan § 300.120
CleanWater Act § '
Oil Pollution Act
CERCLA § 104
PRIMARY AGENCY: The Chief of EPA Region IV's Emergency Response and
Removal Branch (ERRB) will appoint the Incident OSC for each spill. In most cases
it will be the On-call OSC originally sent to the spill. For "worst-case" type spills,
additional OSCs may be needed to fill the variety of roles in the response. All
activities, whether conducted by other OSCs or response personnel, must be
coordinated through the Incident OSC.
SUPPORT AGENCIES: The UCS promotes the coordination between various
parties involved in the response efforts and provides the incident OSC with access to
each. Those parties that work closely with the Incident OSC to provide support are
listed below and presented in detail on the following pages.
a. Discharger or designated Responsible Party representative (if available)
b. Predesignated State representative
c. Representative for the Natural Resource Trustees
d. Local government representatives
e. Regional Response Team
f. EPA Region IV Regional Response Center personnel
g. EPA Region IV Regional Incident Coordination Team
A-4 (update JAN 1995)
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INCIDENT OSC's RESPONSIBILITIES:
Respond in accordance with NCP, USEPA and other agency guidelines.
Direct Federal Superfund or Oil Spill Liability Trust Fund financed response
efforts and coordinate all other Federal efforts at the scene of a discharge or
release.
Ensure that proper response actions have been initiated. If the party
responsible for the release or spill does not act promptly in accordance with the
directions of the OSC or does not take appropriate actions, or if the party is
unknown, the OSC shall respond in accordance with provisions of the NCP,
RCP and agency guidance.
Mobilize, implement and manage the UCS organizational structure needed to
anticipate and accomplish response requirements. Coordinate activities
between dischargers. Federal, State and Local agencies, and private sector
parties. Also, coordinate all field operations by utilizing the UCS.
Assess incident priorities and determine strategic goals and tactical objectives.
Also, develop an Incident Action Plan and ensure each agency implements and
accomplishes those actions for which they are responsible.
Approve response needs and authorize ordering, deploying and demobilization
of response resources.
Serve as the final safety authority, approve the Site Safety Plan and ensure the
maximum achievable level of worker health and safety for all responders.
Work with UCS members and grant final authority to determine end cleanup
operations.
Consult the RRT and keep members informed of response progress through
Pollution Reports (POLREPs).
Obtain proper funding for response activities and set response funding ceilings.
Ensure the following are conducted:
* cost monitoring and documentation
* proper health and safety for responders
* public information and community relations
* documentation of spill and response activities
* natural resource trustees are notified
* Polreps and reports are prepared
A-5 (update JAN 1995)
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RESPONSIBILITIES Continued:
Authorize the use of dispersants, surface collecting agents, burning agents, or
biological additives without obtaining concurrence from the RRT ONLY when
tiie use of the product is necessary to prevent or substantially reduce a hazard
to human life. The Incident OSC must receive concurrence from the RRT to
use such agents if human lives are NOT in immediate danger.
Consults with the Army Corps of Engineers regarding situations potentially
requiring temporary or permanent relocation.
Implement appropriate community relations activities.
Address worker health and safety issues.
Coordinate with the Agency for Toxic Substances and Disease Registry
(ATSDR), as necessary, regarding possible public health threats.
FOR ADDITIONAL INFORMATION
Additional information on the following subjects can be found
in the indicated Annex:
Cost Monitoring
Annex H
Documentation
.• Annex B *.
Funding
Annex H
Health and Safety
Annex G ,:
Natural Resource Trustees
Base Plan & Annex F
Notification
Annex B
Pollution Reports
AnnexB
Predesignated OSCs
Appendix A-1
Public Health
Annex J
Public Relations
.... Annex I
A-6 (update JAN 1995)
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DISCHARGER
SCOPE: The urgent nature of a discharge often requires response initiation before
undertaking extensive enforcement activities. For example, emergencies typically
allow time for only limited enforcement, such as an oral demand for cleanup. In these
circumstances, the NCP gives an OSC the authority to balance enforcement priorities
with those of environmental protection, allowing the OSC to choose the latter as a
means of achieving USEPA's primary goal of protecting public health and the
environment.
If the identity of the responsible party (RP) is known, the Incident OSC shall verbally
inform them of their responsibilities and liability regarding the discharge and response
activities. The Incident OSC shall oversee the work being conducted by the RPs to
ensure compliance with the Facility Response Plan
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STATE and LOCAL REPRESENTATIVES
SCOPE: Section 300.180 of the NCP describes State and local participation in a
response. Ordinarily, State and local public safety officials are the first responders
and initiate public safety measures, consistent with consistent with containment
and cleanup requirements as stated in the NCP, that protect the public health and
welfare. During a response, both State and local officials are involved in the
decision making process. The Incident OSC and these officials should consult with
one another on a regular basis throughout the response. All Federal, State and
local activities should be coordinated to maximize the effectiveness of the
response.
RESPONSIBILITIES: The State and Local representatives shall ensure that the
following actions are completed as appropriate:
Notify downwind communities and downstream water users (municipal,
industrial, and agricultural) of all discharges and releases that may threaten
them or take any initial actions to minimize the impact or damage associated
with the discharge. Inform the Incident OSC regarding
downstream/downwind communities and resources.
Direct evacuations pursuant to existing State or local procedures.
Notify and coordinate with appropriate State, county and municipal
agencies, including State trustees for natural resources and the State
emergency management system.
Serve as liaison between State and Federal government.
Be responsible, in conjunction with the Incident OSC, for:
* Selection of disposal sites and staging areas;
* Arrangement for the use of disposal sites;
* Selection of transport routes to disposal sites;
* Making arrangements with the State Emergency Management Agency
to provide security for ail on-scene forces and equipment. This
includes establishing local liaisons with hospital, emergency services,
and police personnel, and in restricting entrance to hazardous areas to
essential personnel;
* Assist the Incident OSC in determining and providing advice on the
degree of hazard to public health and safety;
A-8 (update JAN 1995)
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RESPONSIBILITIES Continued:
* Assume responsibility for operation and maintenance of a site to the
degree consistent with its authority and resources, if necessary and
when no responsible party has been identified; and,
* Advise the Incident OSC on the use of dispersants and other
chemicals.
Assist in the development of cleanup goals and in determining "how clean is
clean?"
A-9 (update JAN 1995)
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REGIONAL RESPONSE TEAM
SCOPE: As described in Section 300.115 of the NCP, the Regional Response
Team provides assistance and advice to the Incident OSC. During a spill, the
members of the RRT shall make available to the Incident OSC the resources of
their agencies as specified in this plan. Detailed information on the role of the RRT
along with specific members and their resource capabilities is presented in Section
200.2 of the Base portion of this plan.
EPA Region IV Emergency Response and Removal Branch
US Coast Guard, Seventh District*
'NOTE: For Incident specific RRTs, the USCG co-chair will be the representative
from the District in which the spill occurs.
ACTIVATION: An Incident Specific RRT may be activated by either the Incident
OSC, the Co-chair of the agency that provided the Incident OSC, or upon request
of any member agency. Any activation, either partial or full, will normally occur by
telephone and is later confirmed in writing. Procedures for activating the RRT are
presented in Appendix B-3 of Annex B.
RESPONSIBILITIES: The specific role of an Incident RRT is determined by the
requirements of the discharge or release. Some general responsibilities include:
Provide advice, as requested by the Incident OSC, and recommend courses
of action for consideration.
Monitor and evaluate reports from the Incident OSC.
Advise the Incident OSC on the duration and extent of a Federal response
and recommend specific response actions.
CO-CHAIR AGENCIES FOR STANDING RRT:
OTHER MEMBER AGENCIES:
Department of the Interior
Department of State
Department of Commerce
Department of Agriculture
Department of Justice
State Representatives
Nuclear Regulatory Commission
Department of Defense
Department of Energy
Dept. Health & Human Services
Department of Labor
Fed. Emergency Management Agency
Deptartment of Transportation
General Services Administration
A-10 (update JAN 1995)
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RESPONSIBILITIES Continued:
Request other Federal, State and local government or private agencies
provide resources, under their existing authorities, to respond to a discharge
or to monitor response operations.
Provide equipment and resources within the response, resources and
capabilities of the Agency or State. Also assist in the coordination of the
equipment or resources.
Assist the Incident OSC with public information releases.
Consult with the Incident OSC when a request has been made to use
dispersants, surface collecting agents, other chemical agents, burning agents
or biological additives.
J Provide facilities and personnel for communications and information
exchange.
Consult with the National Response Team (NRT) when a discharge or release
exceeds the capabilities of the RRT.
I
FOR ADDITIONAL INFORMATION
Communications
AnnexE
Dispersants/chemical agents
AnnexC
National Response Team
Base Plan
Public Information
Annex I
RRT membership
Base Plan
v 'Reports
AnnexB
Response strategies
Annex C
A-11 (update JAN 1995)
OA !'*
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| REGIONAL INCIDENT COORDINATION TEAM |
SCOPE: The Regional Incident Coordination Team (RICT) operates during
significant, non-routine events that require cooperation and coordination of cross or
multi-program issues within the Region IV EPA office. The RICT does not replace
any existing emergency response organization, procedures or functions. It is a
multi-program team brought together to deal with broad issues during response
events and to support the RRT and the Incident OSC. When the Federal Response
Plan is activated, the RICT will support EPA's ERRS and the various support
functions.
PRIMARY AGENCY: EPA Region IV
MEMBERSHIP: Standing members include senior-level representatives from
each of EPA's Region IV Program Offices. The chair of the RICT is the Chief of the
ERRB. Each member is able to commit resources and make decisions on behalf of
their program. The specific program offices are:
Office of Regional Counsel Office of Congressional Affairs
Office of Public Affairs Office of Policy and Management
Env. Services Division Water Management Division
Wast Management Division Air, Pesticides and Toxics Management
ACTIVATION: Detailed procedures for activating the RICT are included in the
RICT Operational Guidelines. June 1993. Based upon the conditions of the release
and expertise needed, the RICT chair will notify the designated members of the
"Active Status". Once activated, members will be accessible 24-hours a day
unless otherwise notified by the RICT chair.
RESPONSIBILITIES:
Serve as a focal point for overall coordination of EPA Region IV's internal
response efforts and support the Incident OSC in any way possible. Also,
keep the Regional Administrator and other appropriate management apprised
of on-going activities.
Assist the RRT with coordination efforts.
Assist the Emergency Support Functions (ESFs) when the Federal Response
Plan is activated.
Assist in coordination and communication between USEPA Region IV's RRC,
USEPA Headquarters EOC and other Federal and State agencies.
A-12 (update JAN 1995)
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j NATURAL RESOURCES DAMAGE ASSESSMENT i
SCOPE: Subpart G of the NOP discusses in detail Natural Resource Trustees:
designated agencies and their responsibilities. During a response, the Trustees and
the Incident OSC should closely coordinate their activities to facilitate the
fulfillment of each others responsibilities.
PRIMARY RESPONSIBILITY: lies with the Natural Resource Trustees
NOTIFICATION: The Incident OSC should ensure that the Natural Resource
Trustees are notified of the spill event and that site activities are coordinated with
the damage assessment, to the extent possible.
A-13 (update JAN 1995)
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INCIDENT OSC STAFF
- DEPUTY OSC
- SAFETY COORDINATOR
- PUBLIC AFFAIRS LIAISON
- DOCUMENTATION OFFICER
SCOPE:
A-14 (update JAN 1995)
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OSC STAFF: DEPUTY INCIDENT OSC
SCOPE; The Deputy Incident OSC acts as the primary assistant to the incident
OSC and can assume the Incident OSC position, if required. Providing such an
assistant prevents collapse of the UCS when the Incident OSC must attend
briefings and conferences. The Deputy OSC monitors and balances the activities
of the UCS functions, helps establish the flow of information and ensures that the
goals and strategies of the response are accomplished. The Incident OSC can also
establish additional Deputy Incident OSC responsibilities as the response dictates.
PRIMARY AGENCY; EPA Region IV Emergency Response and Removal Branch
RESPONSIBILITIES;
Serve as the OSC in command in the absence of the Incident OSC.
Assist the Incident OSC and other members of the OSC Staff.
Be available for consultation and keep work flowing, especially when the
Incident OSC must attend press conferences and command briefings.
Identify priorities and handle situations related to the internal management
and organizational structure of the UCS.
Assist functions with accomplishing the strategic goals and tactical
strategies defined in the Incident Action Plan.
Receive and ensure distribution of Pollution Reports (POLREPS) and other
communications.
Ensure proper cost tracking and documentation.
A-15 (update JAN 1995)
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OSC STAFF: SAFETY OFFICER
SCOPE; As part of the Incident OSCs immediate staff, the Safety Officer ensures
that all responders, whether governmental or private party, involved in oil spill
response activities comply with all applicable worker health and safety laws and
regulations. This role includes developing a site health and safety plan, ensuring
that all workers are properly trained, arranging training for volunteer workers and
preventing untrained personnel from entering work or contaminated areas. It is
important that the Safety Officer support and monitor the Cleanup Teams and
Advance Teams out in the field as well as the Incident OSC. Depending upon the
size of the response, the Safety Officer may work alone or establish their own
staff. Detailed information on health and safety procedures appear in Annex G.
PRIMARY AGENCIES: EPA Region IV ERRB; USCG Strike Team; OSHA
RESPONSIBILITIES:
Keep the Incident OSC and UCS personnel informed of significant safety and
health issues.
Monitor and assess unsafe situations. Take any necessary measures to
avoid or mitigate these situations.
Write and implement the Site Safety Plan. Ensure that all response
personnel familiarize themselves with the plan and its procedures. Also,
certify that all responders are in compliance with the requirements of the
plan.
Arrange for the availability of medial support both in the field and the local
community.
Ensure that site-related industrial hygiene activities including air monitoring,
medical monitoring, personnel protective equipment selection and worker
decontamination are conducted.
Coordinate with public, government, and industry health and safety officials
regarding public health concerns, including evacuations, limited access to
public areas, beach closures, marina closures and fishing restrictions. Have
health and safety officials evaluate areas that may be affected by an
emergency situation or normal operations and develop a local evacuation
plan.
Identify and conduct required record keeping as specified in the Site Safety
Plan.
A-16 (update JAN 1995)
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RESPONSIBILITIES Continued:
Certify that all responders have adequate skills to safely perform assigned
tasks and that required levels of training are documented. Arrange for on-
site training of volunteers to meet OSHA requirements.
Ensure that site exclusion zones are established and sustained. Post maps in
general areas so all site responders and visitors are aware of the designated
zones.
Identify fire and explosion risks, ignition prevention methods and fire fighting
procedures. Arrange for fire fighting resources to be available during
response operations.
Additional Information
Health and Safety
Strike Team
Advance Teams
Cleanup Teams
Resources
Annex G
Annex J
Annex A
Annex A
, Annex D
A-17 (update JAN 1995)
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OSC STAFF: PUBLIC AFFAIRS LIAISON
SCOPE: In a response situation, the demand for information from the public so
overwhelms the Incident OSC and associated staff that a system for distributing
information must be established immediately. This can be accomplished through
the selection of a public information officer or an entire public information team.
Such a person or team shall consolidate and safeguard the release of information
to the public through radio, television and newspaper. They will also aid the
Incident OSC with all media relations issues. Annex I contains detailed procedures
for public information activities. Federal requirements are presented in § § 300.155
and 300.415 of the NCP.
PRIMARY AGENCIES: EPA Region IV Community Relations Coordinator,
Office of Public Affairs, Office of Congressional Affairs; U.S. Coast Guard, Public
Information Assistant Team (PIAT)
RESPONSIBILITIES:
Prepare, coordinate, and conduct press conferences.
Serve as the liaison between the Incident OSC, the Regional Administrator
and other dignitaries. Ensure that such persons are kept informed of
response activities and related issues. Escort dignitaries that visit the
response scene. Also, assist the Incident OSC with any public issues that
arise.
Maintain communication with other Public Affairs representatives from each
Federal, State, Local and private party at the response.
Identify local media and community representatives and act as liaison
* between them and the Incident OSC. Ensure needs of local contacts are
met in timely, organized manner without interfering with response
operations.
Prepare and distribute joint statements with State, dischargers, and other
Federal agencies. Ensure that information from other parties is accurate and
consistent. Resolve conflicting information through Incident OSC.
Respond to inquiries from citizens, private groups, media and any other
concerned parties.
When necessary, open and staff a Joint information Center (JIC).
A-18 (update JAN 1995)
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OSC STAFF: DOCUMENTATION OFFICER
SCOPE: The accurate recording of response activities and decisions made is
vital to many of the activities that occur days to months after the response is
completed. Such documentation is useful in enforcement and cost recovery cases,
natural resources damage assessments and responder training courses.
Documentation can vary from keeping a simple logbook to recording detailed
expense reports. The Incident OSC shall select a person to coordinate
documentation activities either on their own or through the support of a
documentation team. Further information on documentation requirements is
contained in Sections 300.160 and 300.315 of the NCP and Annex B of this plan.
PRIMARY AGENCIES; EPA Region IV Regional Response Center, EPA
Technical Assistance Team (TAT); USCG Strike Team; Government Services
Administration (GSA)
RESPONSIBILITIES:
Record spill history and on-going response actions and maintain information.
Take photographs and video footage of on-going activities and site
conditions.
Prepare POLREPS and other reports and ensure distribution to the proper
parties.
Prepare or obtain maps needed for response activities.
Conduct administrative activities for Incident OSC and maintain logbook.
Ensure that proper coordination with National Pollution Fund Center and cost
tracking is being conducted by the Finance staff.
Additional Information
Cost Tracking
Annex H
Equipment
Annex D
Logbooks
Annex B
Reports
Annex B
Strike Team
Annex J
Technical Assistance Team
Annex J
A-19 (update JAN 1995)
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FINANCE
- FINANCE OFFICER
- CLAIMS COORDINATOR
- ENFORCEMENT COORDINATOR
- PROCUREMENT COORDINATOR
- COST TRACKER
PURPOSE: The Oil Pollution Act of 1990 improved procedures and availability of
funding for all agencies involved in oil spill responses. The Oil Liability Trust Fund
(OSLTF), managed by the USCG National Pollution Funds Center, provides the
mechanism for financing a response effort. This allows the Incident OSC to secure
additional contractors, personnel and equipment even when the Responsible Party
is conducting the primary cleanup efforts. In addition to USCG funds, EPA
Contracting Officers can also issue contracts for the response effort.
Management of such resources and their costs requires detailed organization and
documentation. The Finance Function assists the Incident OSC by accessing the
OSLTF or EPA Contracting Officer, managing resources, documenting costs and
conducting enforcement activities. Annex H presents detailed funding procedures.
FINANCE OFFICER
SCOPE: The Finance Officer manages the operations that occur within the
Finance function. The function maybe comprised of a complete staff or one
person that performs all roles as well as being the officer. In either case, the
Finance Officer reports financial and enforcement information directly to the
Incident OSC.
PRIMARY AGENCIES: EPA Region IV Contracting Office; USCG National
Pollution Fund Center
RESPONSIBILITIES:
Manage all activities under the enforcement function, ensure adequate
funding is available to conduct the response and prevent costs from
going over established ceilings.
Contact appropriate USCG District to obtain funding or ceiling increases.
Use EPA Contracting Officers to issue funding under warrant authority.
A-20 (update JAN 1995)
GOGS
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FINANCE: CLAIMS COORDINATOR
SCOPE: When a spill occurs it often disrupts the lives and livelihood of many
individuals, not only those responding to the emergency. These individuals may
file claims against the responsible party to receive compensation for any losses
suffered due to the spill. Damages caused by the cleanup effort are often
submitted to the responding agencies. The Claims Coordinator's primary function
is to limit the amount of confusion and disorder that is created as claims are
submitted.
PRIMARY AGENCIES: EPA; USCG; GSA
RESPONSIBILITIES:
Coordinate activities and report claims information directly to the Financial
Officer.
Place advertisements in various media (i.e. radio, television, newspaper)
telling where claims should be sent.
Process claims paperwork.
Coordinate with the responsible party so they can handle claims when
possible.
Coordinate with Joint Information Center or Community Relations
Coordinator to facilitate the distribution of correct information and limit the
number of rumors.
Coordinate evaluation of personal property damage claims directly related to
government agency operations.
A-21 (update JAN 1995)
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FINANCE: ENFORCEMENT OFFICER
SCOPE: The NCP at § 300.415(a)(2) provides that where Responsible Parties are
known, an effort shall be made, to the extent practicable, to determine whether
they can and will perform the necessary response actions promptly and properly.
When the Responsible Party is unknown, an effort should be made to identify and
find them. Given either situation, unknown or known parties, the Enforcement
Officer must take the proper actions to guarantee future recovery of response
costs. The Enforcement Officer also provides support to both the Financial Officer
and the Incident OSC when other legal issues arise.
PRIMARY AGENCIES: EPA Region IV Enforcement Specialist, Office of
Regional Counsel, Office of Criminal Investigations; USCG National Pollution Fund
Center; Department of Justice
RESPONSIBILITIES:
Monitor and regulate bilge discharges from ships not associated with the
spill response.
Provide legal expertise to Incident OSC for supporting response decisions,
mitigating operational problems and preparing civil or criminal actions against
responsible party.
If necessary, collect samples of spilled oil for fingerprinting analysis.
Coordinate with documentation team to collect information to support future
cost recovery or enforcement actions.
Prepare Notice of Federal Interest Letter for Incident OSC.
Prepare Administrative Order.
Coordinate with USCG National Pollution Fund Center for cost recovery.
A-22 (update JAN 1995)
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FINANCE: PROCUREMENT COORDINATOR
SCOPE: Rarely in an emergency do responders arrive on-scene fully equipped to
response to every demand. And, more often, equipment requirements are not
known until response activities get underway. The Procurement Coordinator
provides the funding mechanisms that facilitate the acquisition of needed
resources.
PRIMARY AGENCIES: EPA Region IV ERRB Support Personnel, Contracting
Office,* USCG National Pollution Fund Center; Government Services
Administration
RESPONSIBILITIES:
Coordinate activities with Finance Officer and keep them informed of
procurement information through daily updates.
Provide and ensure financial support for contracting services, purchases and
payments.
Negotiate, coordinate, document and account for all contracts needed to
support response operations.
Coordinate with Resource Coordinator and Logistics Officer to ensure proper
supplies and equipment are purchased.
Work with Cost Tracker to ensure all costs are properly documented and
tracked.
Coordinate activities with NPFC and EPA contracting personnel to ensure
funding mechanisms are accurate.
i
A-23 (update JAN 1995)
00G3
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FINANCE: COST TRACKER
SCOPE: Cost tracking involves documenting the planning and monitoring of all
relevant activities in a legally defensible manner. It includes both the recording of
funds already spent and the management of funds remaining. This ensures that
public funds are expended responsibly while threats to public health, welfare and
the environment are mitigated in a manner consistent with OPA and CERCLA.
Such conscientious cost management also strengthens any governmental claims
for reimbursement made to the Responsible Party. The Cost Tracker assists the
Incident OSC by ensuring that response costs are managed and documented
adequately and accurately.
PRIMARY AGENCIES: EPA Region IV ERRB Support Personnel, Emergency
Response Team, Technical Assistance Team; USCG Strike Team, National
Pollution Fund Center; Government Services Administration
RESPONSIBILITIES:
Coordinate, document and account for response costs based on personnel,
equipment, travel, and other accountable resources.
Coordinate activities with Finance Officer and keep them informed of cost
information through daily tracking updates.
Manage, coordinate and prepare cost documentation and reports in
accordance with NPFC.
Assist State and other government agencies with documentation needed to
process claims through NPFC.
Coordinate with other UCS functions documenting financial expenditures
including logistics, natural resource damages, cleanup costs, related
operational and personnel expenses and projected rehabilitation costs.
A-24 (update JAN 1995)
GO
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LOGISTICS
- LOGISTICS OFFICER
- RESOURCE COORDINATOR
- PERSONNEL and VOLUNTEER COORDINATOR
- TRANSPORTATION COORDINATOR
- TRAINING COORDINATOR
- COMMUNICATIONS COORDINATOR
- SECURITY COORDINATOR
PURPOSE: The success of a spill is often hampered by the inability to effectively
coordinate personnel and equipment. When a response is initiated, it is imperative
that the Logistics function be one of, if not the, first activated to ensure smooth
coordination of resources. As with other functions, individuals may fill one or
several staff positions depending upon the requirements of the release. The
Logistics Function coordinates, but is not limited to, the following items:
Volunteers
Overflights
Distribution
Mobilization
Security
Field Communication
Additional Contractors
Navigation/flow control
Equip/Materials/Supplies
Equipping Workers
Vehicles
Labor Pools
Disposal
Staging Areas
Boats
Lodging
Training
Personnel
Industrial Assistance
FOR ADDITIONAL INFORMATION
Response Resources Annex D
Communications Annex E
Health & Safety Annex G
Funding & Contracting Annex H
Disposal Annex K
A-25 (update JAN 1995)
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LOGISTICS OFFICER
SCOPE: The Logistics Officer, typically an OSC, serves as an assistant to the
Incident OSC; handling any problems associated with the effective utilization of
personnel, equipment and resources in the field. To facilitate coordination, the
Logistics Coordinator operates out of the Incident Command Center and maintains
very close contact with the Logistics staff, the Forward Command Center and field
operations.
PRIMARY AGENCIES: EPA Region IV ERRB; USCG
RESPONSIBILITIES:
Manages the efforts of all members of the Logistics Function. Works closely
with the Incident OSC to ensure that all necessary resources are available to
meet the response objectives.
Works with Logistics staff and Officers from other Functions to resolve
minor issues without burdening the Incident OSC.
Consults with the Incident OSC on all activities that are considered to be
significant to the effectiveness of the response. Provides periodic updates
to Incident OSC on status of personnel, supplies, site security, volunteers
and support.
Works with Officers from other Functions to supply needed resources.
Documents and anticipates resource requirements. Immediately identifies
equipment and personnel needs and sources for meeting those needs.
Guarantees that such items are obtained and ensures their delivery to the
response.
Assists staff Coordinators with deployment of resources to the area of the
response where they are most needed.
Provides assistance to Finance Function in cost tracking.
Makes sure that proper coordination with contracting officers occurs when
contracting issues arise.
Oversees the procurement of lodging, food, training, transportation, and
security for personnel, volunteers and visitors at the response. This also
includes the procurement of building or trailer space for various command
centers and the Joint Information Center.
A-26 (update JAN 1995)
0 0 7 2
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LOGISTICS: RESOURCE COORDINATOR
SCOPE: The success of a response action hinges on the accurate identification,
quick availability and strategic coordination of all resources. Personnel alone can
not sufficiently respond to the demands of an emergency situation. Therefore, the
Resource Coordinator plays a vital and indispensable role in the UCS. Refer to
Annex D for information on response resources.
PRIMARY AGENCIES: EPA Region IV ERRB; USCG; Department of
Transportation; Government Services Administration; US Navy; US Army Corps
of Engineers; State and Local government agencies
SECONDARY AGENCIES: Technical Assistance Team; Contractors; Private
Industry; Local businesses
RESPONSIBILITIES:
Work closely with Logistics Officer to prevent miscommunication and
improper use of resources. Provide periodic status reports.
Coordinate with other Functions to determine equipment needs.
Coordinate with Procurement Coordinator for acquisition of resources.
Document all anticipated and formal request both from the field and made to
the Procurement Coordinator.
Maintain office equipment, computers, copy machines for response support.
Provide and coordinate response facilities location, command posts, incident
operations bases, staging sites, piers, warehouses, communications
facilities, Joint Information Center, berthing, messing and sanitary facilities
and other facilities as needed. Also, provide for necessary facilities in
remote operation locations.
Identify and establish kitchens, galleys, canteens and other food services
support locations. Establish and manage sources of supplies to support
meal and subsistence requirements. Coordinate these sources with
personnel to support and supply response personnel. Also, provide potable
drinking water, coolers and other beverages required.
Maintain stock and inventory of expendable items.
A-27 {update JAN 1995)
f\ f- I* 1
t 1/ • •>
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LOGISTICS: PERSONNEL and VOLUNTEER
COORDINATOR
SCOPE: As with other resources, the success of a response action pivots on the
accurate identification, quick availability and strategic coordination of personnel
and volunteers. Without people, equipment lies idle. Therefore, the Personnel and
Volunteer Coordinator, like the Resource Coordinator, plays a valuable and
indispensable role in the UCS.
PRIMARY AGENCIES: EPA Region IV ERRB; USCG; Government Services
Administration; State and local government agencies
SECONDARY AGENCIES: Government Services Administration; Contractors;
Private Industries; Technical Assistance Team
RESPONSIBILITIES:
Work closely with Logistics Officer and provide periodic status reports on
personnel and volunteer status, availability and costs.
Coordinate with other Functions to determine personnel needs.
Coordinate and document assignment of UCS personnel. Also, coordinate
personnel from government/private sources not assigned by UCS and assign
in accordance with response needs.
Identify, prepare Personnel Locator system to track assignment and location
of personnel and volunteers.
Locate resources from other Function to properly supply personnel and
volunteers with safety and communications equipment. Also, coordinate
with Resource Coordinator for necessary supplies, especially lodging.
Inform Training Coordinator of number of personnel and volunteers that
require training. Assist in development of training time frame.
Process incoming and outgoing personnel and volunteers.
Coordinate with established volunteer agencies and designate assignments.
Identify and account for all volunteers.
Manage volunteers in operational response areas.
A-28 (update JAN 1995)
CO
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LOGISTICS: TRANSPORTATION COORDINATOR
SCOPE: The Transportation Coordinator provides transportation assistance to
Federal, State and local governmental entities and volunteers. Such coordination
assures smooth movement of resources and prevents a collapse in operations.
Annex K contains more information on disposal.
PRIMARY AGENCIES: Department of Transportation,* EPA Region IV; USCG
SECONDARY AGENCIES: State and Local government agencies;
Contractors; Private Industry
RESPONSIBILITIES:
Work closely with Logistics Officer and provide periodic status reports on
transportation status, availability and costs.
Coordinate with other Functions to determine transportation needs.
Manage and maintain dedicated transportation resources. When necessary,
arrange for the transport and delivery of response equipment, materials,
supplies.
Provide expertise pertaining to transportation of oil or hazardous substances
by all modes of transportation, including the requirements for packaging,
handling and transporting regulated material.
Work with contractors, facilities and the State to arrange for transport of
recovered material, debris and refuse to the final disposal site.
Provide, prioritize, schedule and coordinate response transportation services.
Identify additional transportation resources.
Obtain resources for personnel and visitor transport. This includes both over
land and water transportation.
When necessary, arrange for air transportation and spill-area overflights.
Work with Procurement Coordinator for funding assistance.
A-29 (update JAN 1995)
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LOGISTICS: TRAINING COORDINATOR
SCOPE: Given the large response crews, the rush of volunteers and the
overwhelming public interest, site activities can quickly fall into chaos. Suitable
training for all responders safeguards against unnecessary accidents and regulatory
violations. Consult Annex G for health and safety information.
PRIMARY AGENCIES: EPA Region IV; EPA Emergency Response Team;
USCG Strike Team; Occupational Safety and Health Administration
RESPONSIBILITIES:
Work closely with Logistics Officer and provide periodic status reports on
training status and costs.
Work with Personnel and Volunteer Coordinator and Safety Coordinator to
establish training needs. Ensure that all responders have adequate skills to
safely perform assigned tasks and that required level of training is
documented.
Provide health and safety training for responders, both paid and volunteer. If
necessary, coordinate with OSHA representative.
Identify and provide any additional training needed to ensure a smooth
response effort.
Work with wildlife groups to train volunteers on safe capture and transport
of oiled and injured animals.
A-30 (update JAN 1995)
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LOGISTICS: COMMUNICATIONS COORDINATOR
SCOPE: The Communications Coordinator provides resources vital to maintaining
a dependable flow of information between all responders. Without which,
coordination would be impossible. Annex E contains more information on
communications and available resources.
PRIMARY AGENCIES: EPA Region IV; USCG Strike Team, National Strike
Force Coordination Center; Federal Emergency Management Agency; State and
Local government agencies
SECONDARY AGENCIES: National Pollution Fund Center; US Navy;
US Army; General Services Administration; Ham Radio Operators
RESPONSIBILITIES:
Work closely with Logistics Officer and provide periodic status reports on
communications status.
Determine communication needs and logistics for Incident Command Center
and field command centers.
Work with Resources Coordinator to acquire all necessary communications
equipment and distribute to responders.
Establish communication schedule with field responders.
Coordinate maintenance and transportation of all communications
equipment.
Troubleshoot problems with communication equipment. Arrange for
replacement equipment and backup systems.
A-31 (update JAN 1995)
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LOGISTICS: SECURITY COORDINATOR
SCOPE: The Security Coordinator eliminates disorder generated by random
access to response areas and lost time created by stolen or damaged equipment.
Such conscientious security practices eliminate excess stress on response
personnel.
PRIMARY AGENCIES: Local and government agencies; US Army; National
Guard
SECONDARY AGENCIES: EPA Region IV; USCG; Contractors
RESPONSIBILITIES:
Work closely with Logistics Officer and provide periodic status reports on
security issues and costs.
Identify security needs for each Function, field team, command center, and
other response areas.
Arrange, coordinate and hire security equipment and personnel to support
response activities.
Establish system for identifying response personnel, volunteers and visitors.
Set up a central point for entering and exiting each response area and
command centers. Manage the access non-approved persons have to these
areas and centers.
A-32 (update JAN 1995)
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PLANNING
- PLANNING OFFICER
- ADVANCE TEAMS COORDINATOR
- HOW CLEAN IS CLEAN? TEAM
- DISPOSAL COORDINATOR
- SCIENTIFIC SUPPORT COORDINATOR
* RISK ASSESSMENT
* ENVIRONMENTAL SENSITIVITY
PURPOSE: The Planning Function, comprised of a staff of technical experts and
experienced emergency responders, works in cooperation with the Planning Officer
to create the best response strategy possible. It is this strategy, called the Incident
Action Plan, that guides all response efforts. The Planning Function also monitors
activities to ensure that equipment and personnel resources are effectively located
and utilized. As with other Functions, individuals may fill one or several staff
positions depending upon the requirements of the release.
FOR ADDITIONAL INFORMATION
Response Resources Annex D
Communications Annex E
Health & Safety Annex G
Funding & Contracting Annex H
Disposal Annex K
Environmental Sensitivitey Annex F
A-33 (update JAN 1995)
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PLANNING OFFICER
SCOPE: The Planning Officer, usually an experienced OSC, assists the Incident
OSC by creating response strategies, recognizing resources needs and balancing
response activities.
PRIMARY AGENCIES; EPA Region IV ERRB; USCG
RESPONSIBILITIES:
Ensure all necessary permits are obtained.
A-34 (update JAN 1995)
000
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PLANNING: ADVANCE TEAMS COORDINATOR
SCOPE: The Advance Teams Coordinator operates as the liaison between field
activities and the command centers. Refer to Annex C for information on oil spill
response strategies.
PRIMARY AGENCIES: EPA Region IV ERRB; USCG Strike Team
RESPONSIBILITIES:
Work with Planning Officer to coordinate efforts according to the Incident
Response Plan.
Identify areas downstream or downwind that may be adversely impacted by
the release, especially sensitive environments and drinking water intakes.
Assess potential impacts of the spill moving into area.
Notify and coordinate with appropriate parties downstream or downwind
{i.e. Resource managers, city officials, water managers).
Prioritize areas for protection. Coordinate with Scientific Support
Coordinator and other government agencies to identify sensitive areas.
Develop and implement protection strategies based on response priorities.
Put in place physical barriers to deter spread of oil or to protect natural
resources, water intakes, or any other areas that may be adversely
impacted.
Coordinate with scientific team to obtain information from trajectory models.
Find and clear areas to facilitate the access of personnel and equipment to
the areas that require protection or cleanup.
Identify and prepare areas for temporary storage of recovered materials and
debris.
A-35 (update JAN 1995)
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ADVANCED TEAMS
SCOPE: During a response, the Advance Teams are responsible for travelling
downstream or beyond the perimeter of the spill taking preventative measures to
mitigate any potential damage. Teams can consist of contractors, USCG Strike
Team members, or any other trained personnel available. Teams will be lead by an
OSC.
RESPONSIBILITIES:
Identify sites for placement of booms and other containment equipment.
Provide Advance Team Coordinator and Cleanup Team Coordinator with
recommendations on equipment and manpower needs.
Identify locations of sensitive habitats and endangered species including type
and number that may require recovery and rehabiiiations. Keep wiidiife
rescue teams apprised of these locations.
Identify or clear areas for equipment access to the spill.
When possible, place defelection boom downstream of plume in areas
needed protection.
A-36 (update JAN 1995)
0002
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PLANNING: HOW CLEAN IS CLEAN? TEAM
SCOPE: In every response to a release there comes a point where the ability
remove the material becomes more difficult and costly than in the beginning.
When such a point is reached, decision makers must evaluate If the material
remaining still has the potential to cause a significant impact and if the impact
justifies the increased effort and cost. To facilitate the decision, the Incident OSC,
State Trustees, and associated RRT members should meet early in the response to
determine cleanup standards for the spill. All response activities should be geared
towards meeting these standards.
PRIMARY TEAM MEMBERS: Incident OSC; Discharger (if available); State
and Local government representatives; Planning Officer; Logistics Officer;
Finance Officer; Response Operations Officer; Natural Resource Trustees; other
representatives as selected by Incident OSC
RESPONSIBILITIES:
Meet at the beginning of response activity to develop an Incident Action
Plan to outline cleanup goals and develop cleanup standards.
Meet with Planning Coordinator at scheduled intervals throughout response
to monitor consistency with Incident Action Plan
Set standards for determining when enough is enough.
Conduct long-term monitoring of structures that are put in place to recover
or divert material (i.e. interceptor trenches, passive recovery systems,
underflow dams). Determine when these structures can be removed.
FACTORS TO CONSIDER: Because the decision to end cleanup activities and
all natural degradation of remaining oil must be made on a case-by-case basis, the
following factors should be considered:
1. Is the irreversible environmental damage from cleanup operations greater
than the environmental damage from leaving oil in place?
2. Are cleanup costs increasing while oil removal is significantly decreasing?
3. Does the Incident OSC and the other decision makers feel that response
efforts are becoming more difficult without showing substantial
improvement to the environment?
4. Do only patchy areas of material remain?
A-37 (update JAN 1995)
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PLANNING: DISPOSAL
SCOPE: As a response progresses, attention shifts to the removal and disposal
of the spilled material. This often creates an entirely new set of problems that, if
not addressed, shut down the entire response operations. To solve these problems
requires coordination between Federal, State, Local and private agencies. The
Disposal Coordinator must rely on these other agencies for information on
treatment options, disposal facilities, permit requirements and any other related
issue. Annex K, Disposal, should also be consulted.
PRIMARY AGENCIES: EPA Region IV; USCG; State and Local government
agencies
RESPONSIBILITIES:
Keep Planning Officer updated on key issues related to storage and disposal
issues. Also, assist Planning Officer in obtaining any necessary government
permits for the removal of oil or hazardous materials.
Develop a disposal plan to detail the collection, temporary storage,
transportation, recycling and disposal of all anticipated response wastes;
detailing sites and methods of hazardous material disposal, including
contaminated land, beaches and wildlife cleaning wastes.
Evaluate and recommend to Planning Officer the best disposal options for
various waste streams.
Consult with State representatives regarding waste disposal issues.
Ensure the chosen disposal facility is in current compliance nor has other
issues that would interfere with proper disposal.
Ensure that the Incident OSC signs all hazardous waste manifests.
Work with Transportation Coordinator to arrange for safe and appropriate
transportation of waste.
Work with Resource Coordinator for the acquisition of waste storage
equipment. Make sure that field teams receive and properly utilize storage
equipment.
Coordinate with Advance Teams and Cleanup Teams so specific field
disposal and storage needs are met.
A-38 (update JAN 1995)
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PLANNING: SCIENTIFIC SUPPORT COORDINATOR
SCOPE; When responding to an oil or hazardous substance release the Incident
OSC and other responders must be able to draw upon the scientific and technical
knowledge of experts in subjects such as chemistry, wildlife biology, hydrology,
and engineering. Gathering such experts together and keeping them organized
requires someone's full time attention. Due to the other demands placed upon the
Incident OSC, it is often necessary to enlist the support of a Scientific Coordinator
who will be the liaison between the responders and the scientific community.
Annexes C, F and J contain detailed procedures for conducting scientific support
activities.
PRIMARY AGENCIES: EPA Emergency Response Team, Environmental
Services Divisions,* NOAA Scientific Support Coordinator; USCG Strike Team;
Technical Assistance Team; US Fish and Wildlife Services
RESPONSIBILITIES:
Coordinate the activities of the scientific support team members. Keep
Planning Officer informed regarding related issues and serve as a close
technical advisor to the Incident OSC.
Work closely with How Clean Is Clean? Team when developing Incident
Action Plan and making response decisions.
Review and recommend response strategies and technologies to the Disposal
Coordinator and the Planning Officer.
Assist with response priorities determination.
Coordinate response activities with research studies.
Develop trajectory models and impact predictions.
Assist with natural resource damage assessments by working with Natural
Resource Trustees and resource managers.
Review new product information and serve as the point of contact for
product sales representatives.
Prepare and implement sampling and monitoring plans to determine the
extent of contamination and the effectiveness of cleanup actions.
A-39 (update JAN 1995)
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RISK ASSESSMENT
SCOPE: Concerns over the effect of the release on human health often arise
during a response. Typically, the Incident OSC is not technically qualified to
address specific public health questions and must defer to a more qualified person,
such as an industrial hygienist or toxicologist. Section 300.175 of the NCP
discusses the agencies that provide public health assistance. Annex J of this Plan
also discusses the role of a public health advisor during a response.
PRIMARY AGENCIES: EPA Emergency Response Team (ERT), Toxicologist,
Water Division and Air Division through the RICT; Agency for Toxic Substances
and Disease Registry; Local Health Department
RESPONSIBILITIES:
Keep Planning Officer, Scientific Support Coordinator and Incident OSC
informed of all notable issues. Serve as a close technical advisor to the
Incident OSC.
Work closely with How Clean Is Clean? Team when developing Incident
Action Plan and making response decisions.
Assist in providing alternate water supplies and address water treatment
issues.
Make health assessment and prepare health advisories.
Assist in air monitoring, if necessary.
Provide advice to the incident OSC on health issues, evacuations,
toxicology, risk assessments and any other public health problems that may
arise.
A-40 (update JAN 1995)
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ENVIRONMENTAL SENSITIVITY
SCOPE: Commonly in a response, the Incident OSC faces the difficult challenge
of deciding which resources need protection and which can withstand exposure to
the spilled material. These decisions typically fall outside the Incident OSC's
technical expertise. Personnel with specialized knowledge in habitat and wildlife
sensitivity become integral players throughout the entire response. Annex F
contains information on environmental sensitivity.
PRIMARY AGENCIES; Department of Interior - US Fish and Wildlife
Service; State and Local Agencies; NOAA
RESPONSIBILITIES:
Keep Planning Officer, Scientific Support Coordinator and Incident OSC
informed of all notable issues. Serve as a close technical advisor to the
Incident OSC.
Work closely with How Clean Is Clean? Team when developing Incident
Action Plan and making response decisions.
Assess impacts of response activities on natural resources and environment.
Make recommendations to Planning Officer and Incident OSC on protection
priorities and strategies.
Ensure coordination with US Fish and Wildlife Service along with State and
Local agencies. Also, keep Natural Resource Trustees apprised of on-going
activities.
A-41 (update JAN 1995)
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OPERATIONS
- OPERATIONS OFFICER
- CLEAN-UP TEAMS COORDINATOR
- WILDLIFE RECOVERY COORDINATOR
PURPOSE: The Operations Function, comprised of experienced emergency
response personnel, works in cooperation with the Operations Officer to manage
all field operations directly related to the control, containment and cleanup of any
spilled or emitted material, the operation of all equipment pertaining to the incident,
the coordination of all agencies responsible for safety and protection, and the
temporary storage and disposal of contaminated and spilled material. Through this
Function, all plans are put to real-time use in the field. The other UCS Functions
provide assistance, resources and advice to the Operations Function for a
successful cleanup with minimal environmental damage. The Operations Function
is also the key element for relaying field information back the Incident OSC and the
other Functions. Depending upon the size of the response, individuals may fill one
or several Operations Function positions.
FOR ADDITIONAL INFORMATION
Response Strategies
Response Resources
Health & Safety
Funding & Contracting
Disposal
Environmental Sensitivity
Annex C
Annex D
Annex-G
Annex H
Annex K
Annex F
A-42 (update JAN 1995)
0C8S
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OPERATIONS OFFICER
SCOPE; The Operations Officer, an experienced responder, assists the Incident
OSC with monitoring and managing the field response operations. It is this
Officer's duty to ensure that planned response activities actually occur in the field;
and, when plans cannot be carried out, makes recommendations to the Incident
OSC. The Operations Officer operates out of the Incident Command Center and
maintains extremely close contact with the Forward Command Center and field
operations.
PRIMARY AGENCIES: EPA Region IV ERRB; USCG; Response Contractors
RESPONSIBILITIES:
Manage the efforts of all members of the Operations Function. Works
closely with the Incident OSC to ensure that all necessary resources are
utilized to meet the response objectives.
Work with Operations staff and Officers from other Functions to resolve
minor issues without burdening the Incident OSC.
Consult with the Incident OSC on all activities that are considered to be
significant to the effectiveness of the response. Provides periodic
updates to Incident OSC on status of personnel, supplies, site security,
volunteers and support.
Work with Officers from other Functions so needed resources are
obtained.
Develop operational assignments, schedules and duty lists to accomplish
strategic response goals and objectives. Work with How Clean Is Clean?
Team on development of incident Action Plan.
When necessary, evaluate and report on response countermeasure
efficiency.
Document and anticipate resource requirements. Coordinate with other
Functions to obtain necessary supplies, equipment and personnel
resources. Ensure that such items are obtained and delivered to the
response.
Assist staff Coordinators with deployment of resources to the area of
the response where they are most needed.
I
A-43 (update JAN 1995)
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OPERATIONS: CLEANUP TEAMS COORDINATOR
SCOPE: The Cleanup Team Coordinator manages the Cleanup Teams which
work in the field to contain, mitigate and remove the spilled material. Teams
consist of response contractor personnel.
PRIMARY AGENCIES: EPA Region IV ERRB,* USCG Strike Team; State
Representative; Contractors
RESPONSIBILITIES:
Manage the efforts of the Cleanup Teams. Work closely with the Operations
Officer to ensure that all necessary resources are utilized to meet the
response objectives.
Work with Operations staff and Officers from other Functions to resolve
minor issues without burdening the Incident OSC.
Consult with the Operations Officer on all activities that are considered to be
significant to the effectiveness of the response. Provide periodic updates to
Incident OSC on status of personnel, supplies, site security, volunteers and
support.
Coordinate personnel and equipment deployment.
Control the source of discharge and minimize the spread of the spill.
Conduct salvage operations, if necessary.
If possible, use chemicals or other materials to enhance collection or
remediation of spilled material. Consult with Subpart J of the NCP, the
Incident OSC and the RRT before using such chemicals or materials.
Coordinate activities with Advance Teams, keep them informed of on-going
and planned activities.
Work with Scientific Support Coordinator to collect samples of water and
spilled material and arrange for their analysis.
Monitor activities to ensure compliance with health and safety requirements.
Work with Disposal Coordinator to arrange for temporary storage and
disposal of recovered materials, debris and refuse.
A-44 (update JAN 1995)
009
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CLEANUP TEAMS
SCOPE: Cleanup Teams contain, mitigate and remove the spilled material to
minimize the effects on health, welfare and the environment. Teams consist of
response contractor personnel and an OSC or State representative for oversight.
RESPONSIBILITIES: Cleanup Team responsibilities involve several key tasks:
A. Containment Operations
Direct the delivery, deployment and operation of response equipment to
contain material, either on land or water.
Perform operations to stop the release of material into the environment.
Place protection and/or deflection booming in identified sites. Coordinate
with Advance Teams for these identified locations.
B. Recovery Operations
Conduct skimming and surface recovery operations. Provide Cleanup Team
Coordinator with status reports. Maintain estimate of volume of material
recovered.
Work with Disposal Coordinator for storage, transport and disposal of
recovered material.
C. Shoreline Cleanup Operations
Utilize equipment and personnel to cleanup spilled material from shoreline.
Report to Cleanup Team Coordinator on efficiency of shoreline recovery and
cleanup.
A-45 (update JAN 1995)
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OPERATIONS: WILDLIFE RECOVERY COORDINATOR
SCOPE; When cleaning up a major spill, responders must remember to include
the impacted wildlife. The Department of the Interior's Fish and Wildlife Service
(USFWS) issue and maintain permits for private and volunteer wildlife rescue
groups for the purpose of hazing, capture, triage, care and transport. These rescue
groups can respond to a spill within several hours and come fully equiped. During
a response, names and phone numbers for permited groups can be obtained
through the USFWS or State contacts.
PRIMARY AGENCIES: Private Wildlife Rescue Programs
RESPONSIBILITIES:
Manage wildlife recovery and capture operations in accordance with Federal
and State laws.
Work with Operations staff and Officers from other Functions to resolve
minor issues without burdening the Incident OSC.
Consult with the Operations Officer on all activities that are considered to be
significant to the effectiveness of the response. Provide periodic updates to
Incident OSC on status of personnel, supplies, site security, volunteers and
support.
Contact and coordinate with pre-identified wildlife recovery and rehabilitation
centers. Coordinate with volunteer centers and facilities for space to
conduct rehabilitation activities.
Coordinate logistics requirements to accomplish hazing, capture, triage, care
and transport.
Maintain central clearing point to direct recovered wildlife to appropriate
rehabilitation facilities.
A-46 (update JAN 1995)
0 08 2
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NOTIFICATION, COMMUNICATION, REPORTS
PURPOSE: Notification concerning an oil or hazardous substance release or
discharge is the foundation for all response operations and is required under
Federal Law (CWA, OPA and CERCLA). Timely and accurate information must be
provided to the proper agency to begin any protective action.
SCOPE: This Annex provides guidance on the initial actions to activate a
response, provide coordination among the members of the response organization,
and keep those members informed of the latest developments in the response.
RESPONSIBILITIES: It is the spider's responsibility to report all spills. If U.S.
USEPA or USCG is the first to be notified of a release or discharge, either will
notify, as appropriate, the State and the National Response Center (NRC), the
appropriate trustees for natural resources, and other RRT members. If the State or
another agency is the first to be notified, they shall notify the NRC.
Any person may undertake a response action to reduce or remove a release of a
hazardous substance, pollutant, or contaminant. Such participation in response
action by persons other than the first Federal official is discussed in the NCP,
Subpart H, and remains unchanged in this plan.
I. NOTIFICATION AND ACTIVATION PROCEDURES:
A. It is the spiller's responsibility to report all spills in accordance with 40 CFR
300.300(b) for oil discharges and 40 CFR 300.405(b) for hazardous
substance releases.
B. Spill reports are forwarded to the Region IV Telephone duty OSC (TEL). The
TEL will confirm the report, gather additional information as necessary, and
make a decision on the appropriate federal response. Procedures for
determining release classification and appropriate notification actions are
contained in Appendix B-1.
C. The TEL will ensure that the state environmental agency and the natural
resource trustees are notified of the incident, as appropriate. Appendix B-2
outlines special notification procedures.
All contact names and phone numbers for organizations discussed in this plan are contained in USEPA
ERRB's Blue Book. Each USEPA designated OSC has been issued an official copy. One additional copy
is kept in the RRC for reference.
B-1
C 0 0 3
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D. For all major spills and other spills which, because of their location or other
circumstances are likely to generate a great deal of media attention, the TEL
will notify section or branch management who will in turn inform senior
regional management.
E. For major spills, or natural disaster responses under the FRP, the following
actions should be considered:
1. Activate Regional Response Center
2. Determine the availability of additional OSCs
3. For oil spills, obtain Federal Project Number and Project Ceiling; For
hazardous substance spills, obtain ????
4. Coordinate with responder and dispatch resources such as TAT,
USCG Strike Team, and Cleanup Contractor(s)
5. Activate Regional Incident Coordination Team (RICT) and Regional
Response Team (RRT). Activation procedures are explained in
Appendix B-2.
6. Notify Backup Regions
7. Activate Helicopter Contract
8. For spills into water, ensure that downstream users are notified
9. Notify USEPA Headquarters and update National Response Center
II. COMMUNICATION PROCEDURES:
The key to success on any response operation is clear and open communications.
Information on communications hardware and frequencies is detailed in Annex E,
Communications. This annex will outline general information flow and
communications policy for a response.
A. Establishing On-Scene Communications:
The Responding OSC should take immediate steps to establish at least a temporary
means of communicating with local responders, the RRC, and field teams. As the
response develops the OSC should work toward installation of a more permanent
and more reliable system. In setting up the communications network, the OSC
should consider the following:
1. Establish communication with the local fire and police departments.
2. Assess local communications systems and capabilities.
3. Mobilize and set up Mobile Command Post.
4. Set up communications network.
5. Locate and mobilize communications devices.
6. Provide field teams with appropriate communications equipment.
7. Set up Joint Information Center to coordinate all press releases.
B-2
G 0 0 4
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B. Communication During Incident:
Generally, all conference calls will be conducted through the NRC conference
bridge which has up to 100 telephone lines available. With the NRC conference
bridge, each participant is assigned a unique telephone number for the call.
Arrangements for a conference call should be made in advance by the NRC.
Because time during a response is extremely valuable, calls should begin on time
and conversation should be tightly controlled by the RRT chair.
1. RRT Conference Calls: RRT conference calls will be conducted as needed to
provide information on the incident to RRT members, coordinate the supply
of response resources, provide advice to the OSC, or to make response
decisions. The RRT Chair will determine the frequency of these calls.
NOTE: The need for information should not in any way interfere with the
ongoing response action.
2. Incident Management Calls:
a. Intra-reaional Conference Calls: It is important that all USEPA responders
be kept aware of ongoing developments and concerns. As a means of
conveying this information to responders in the field, the region will attempt
to have conference calls daily through the RRC.
b. Operational Communications: Operational communications for incidents
responded to under this Plan will be set up in a step down approach so that
each decisions making or informational level of the response organization is
aware of a sufficient degree of detail on issues to make informed decisions.
Members of the response organization should not bypass this
communication structure since such actions can lead to unsubstantiated
rumors, misdirected assignments or repeated conveyance of information.
(1). Field Components to Contractors or Other Agencies: All response
resources will be dispatched through a staging area under the control of the
Logistics OSC to be set up in the earliest stages of response. Each
organization will beassigned a task, given a health and safety briefing, and
provided with a means of communication back to the Task Leader (OSC) or
Logistics staff. RRT member agencies acting under their own statutory
authorities should inform the Incident OSC of their activities and findings.
(2). Field Components to Incident Command Post: Field components
overseeing the various tasks will maintain contact with the Logistics staff.
They will not normally be expected to participate in RRT Conference Calls.
(3). Incident Command Post to RRC: The RRC will contact and coordinate
with field components through the Incident Command Post on an as needed
basis.
B-3
093
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14). RRC to USEPA Headquarters: The RRC will provide USEPA HQ with
updates on the incident. HQ should not contact field components directly.
3. Regional Response Center: The RRC will be the Incident's primary means of
information management and resource coordination. RRC responsibilities are
summarized below:
a. Information Management
(1). Briefings for RRT, RICT, Senior Management, and Headquarters
(2). POLREP distribution
(3). Maps
(4). GIS applications
b. Resource Coordination
(1). Status Boards
(2). RICT resources
(3). RRT resources
(4). Resources from other USEPA regions
(5). Contracting coordination/documentation
4. Joint Information Center: It is extremely important to keep the JIC informed
of all ongoing activities. Accordingly, a JIC representative will be included in
all incident-related conference calls. Additional details on the role of the JIC
are discussed in Annex I, Public/Community Information.
The high degree of media interest to an emergency response often promotes the use of scanners to
monitor radio and cellular telephone communications. Conversations should be kept on a strictly
professional level at all times.
III. REPORTS PROCEDURES:
Information to be included in each report and the format are presented in Appendix
B-4.
A. Damage Assessment/Response Tracking Forms: These will be used to
ensure that reports of damage are investigated and properly resolved. They
are also designed to aid in the preparation of an after action report.
B. Incident Logs: The Incident OSC shall maintain an accurate Incident
Logbook. The RRC will also maintain a logbook of the Incident to document
information not likely to be captured in the field.
B-4
009
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C. POLREPs and SITREPs: Each incident will have an Initial and Final POLREP
or SITREP. POLREPs are prepared by the Incident OSC and are used for
discharges of oil or releases of hazardous substances. SITREPs are prepared
by the Branch Chief for any other type of incident. The frequency of
progress POLREPs will be determined by the Incident OSC. The frequency
of SITREPs will be determined by the Branch Chief. In no case will POLREPs
or SITREPs be issued less frequently than weekly. Distribution of these
documents will vary by the type of incident and will be determined by the
preparing official. These documents will either be hand delivered or faxed to
the addressees.
D. Cost Documentation: Appropriate cost documentation procedures are
detailed in the Oil Spill Response Checklist.
E. Enforcement Documentation: Enforcement documentation requirements are
outlined in Attachment VI of the Oil Spill Response Checklist.
F. OSC Report/After Action Report: The After Action report should be
prepared in accordance with 40 CFR 300.165.
G. Debriefing/Critique: After completion of response actions at each major
incident, the region will conduct a debriefing or critique of the response. A
session consisting of the USEPA participants, at a minimum, will be held to
discuss both the positive and negative aspects of the response in an effort
to improve future responses. Lessons learned during the incident will be
incorporated into future modifications to the RCP, as appropriate.
B-5
c e 81
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APPENDIX B-1
CLASSIFICATION OF OIL AND
HAZARDOUS SUBSTANCE RELEASES
I. OIL RELEASES
A. MINOR
For minor oil spills (those under 1,000 gallons) the OSC will, if circumstances
warrant, send (via FAX, E-Mail, or other means) incident notification reports or
POLREPs to the appropriate Regional Response Center (RRC), the appropriate
State(s), and appropriate Federal and State natural resources trustees. These
reports will be reviewed by the RRT Co-Chairs or their designees, who will notify
other Federal and State RRT members, if circumstances warrant. (Note: Very small
spills, i.e. less than 100 gallons, will usually not require action or notification of
RRT Co-Chairs.)
B. MEDIUM
Actual or potential medium oil spills (those between 1,000 and 10,000 gallons),
will be treated the same as minor spills unless response requirements exceed the
capabilities of the OSCs and local contractors, or when there is a likelihood of
strong public or political interest in the response, or of major environmental
damage. Under these circumstances, the required notifications for a major spill will
be initiated.
C. MAJOR
Upon first learning of an actual or potential major oil spill situation (in excess of
10,000 gallons), the OSC, if not already in the RRC, shall immediately notify the
RRC by the most rapid means available. The OSC shall provide the RRC with all
known information, even if it has not been confirmed by personnel on-scene.
Upon notification, the RRT Co-Chair(s) shall determine whether to activate the RRT
for information purposes. RRT activation will be by telephone, followed by RRC
POLREPs.
D. WORST CASE
Follow the same procedures for a major spill. It will be up to the RRC and the RRT
Co-Chair(s) to determine if the spill is a worst case. Further response actions shall
follow the procedures presented in this plan.
Appendix B-1-1
0 0 0 3
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II. HAZARDOUS SUBSTANCES RELEASES
A. MINOR
For minor releases, those in an amount of less than the reportable quantity (RQ,
established in 40 CFR 300 and 355) that poses minimal threat to human health or
welfare or the environment, the OSC will, if circumstances warrant, send routine
(in lieu of Priority) incident notification reports or POLREP message reports to the
RRC and appropriate trustees for natural resources. These reports will be reviewed
by the RRT Co-Chairs or their designees, who will notify other Federal and State
RRT members if circumstances warrant.
B. MEDIUM
Actual or potential medium releases (those amounts exceeding the RQ which do
not meet the criteria for classification as a minor or major release) will be treated
the same as minor spills, unless response requirements exceed the capabilities of
the OSC and local contractors, or when there is a likelihood of strong public or
political interest in the response. Under these circumstances the required
notifications for a major spill will be initiated.
C. MAJOR
Upon first learning of an actual or potential major hazardous substance release in
an amount that poses a substantial threat to human health, welfare, or the
environment, or results in significant public concern, the OSC, if not already in the
RRC, shall immediately notify the RRC by the most rapid means available. The
OSC shall provide the RRC with all known information, even if it has not been
confirmed by on-scene personnel.
Upon notification of an actual or potential major hazardous substance release, the
RRT Co-Chairs shall determine whether to activate the RRT for information
purposes. RRT activation will be by telephone, followed by RRC POLREPS.
Appendix B-1-2
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APPENDIX B-2
SPECIAL NOTIFICATION SITUATIONS
In some situations, the TEL (Telephone Duty-OSC) will have to notify organizations
other than the States or members of the RRT. Listed below are those
organizations involved in special notification situations and the procedures for
handling them.
A. State Natural Resource Trustee: The State pollution response agency
notified of a release by the OSC will in turn alert the State natural resource
trustee.
B. Federal Land Manager: When a release impacts Federal property, such as a
National Forest, the OSC will notify the local office of the managing agency.
If he/she is unable to promptly make this notification, he/she will alert the
RRT representative for the managing agency.
C. National Response Center (NRC): OSCs are not required to notify the NRC
of releases. However, in that very rare circumstance where an OSC receives
a report from the responsible party and the responsible party is unable to
contact the NRC, the OSC will relay the report to the NRC. USCG OSCs
may accomplish this by entering the NRC Port Code in the notify slot which
follows the MPIR screen of the MSIS Marine Pollution Product Set.
D. Ohio River: Ohio River Valley Water Sanitation Commission's (ORSANCO)
Emergency Response Resource Manual includes a spill notification plan for
use by ORSANCO and by State and Federal agencies. The ORSANCO plan's
spill response procedures, kept in the USEPA RRC, apply to spills into the
Ohio River and its tributaries. It specifies that USEPA, State water pollution
control agencies, USCG, and ORSANCO will notify each other of spills, but
allows for ORSANCO to assist in notifying the appropriate agencies of
"adjacent and downstream States". Under the plan, the State water supply
agencies carry the responsibility for alerting water users.
E. Local Notifications: It will be up to the State RRT representative to notify
local community officials in the area affected by the release.
Appendix B-2-1
0109
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APPENDIX B-3
ACTIVATION OF THE RRT
The incident-specific RRT may be activated by any member agency when a
discharge or release:
1. Exceeds the response capabilities available to the OSC in the place where rt
occurs;
2. Transects State, Regional and/or international boundaries;
3. Poses a substantial threat to public health, welfare, or to the environment, or
to Regionally significant amounts of property.
The Co-Chair will activate the RRT during any discharge or release upon request
from the OSC or from any RRT representative. Requests for RRT activation shall
subsequently be confirmed in writing. Local requests for RRT activation must be
made through the State RRT member.
During a prolonged removal action, activation of the RRT may be unnecessary or it
may be activated in only a limited sense, or have available only those members
who are affected or can provide direct response assistance. When the RRT is
activated, affected States may participate in all RRT deliberations. When the RRT
is assembled, the RRT shall meet at a time and location specified by the Chair.
Levels of activation are listed below. Activation may occur by phone or by
assembly.
Alert: Notification of RRT members that an incident has occurred.
Standby: Notice to some or all RRT members that their services may be
needed and that they are to assume a readiness posture and await
further instructions. Notice may be given by phone.
Partial: Notice to selected RRT members that their services are required in
response to a pollution incident. The activation notice will specify the
services that will be required. Although the services of only selected
members are being requested, partial activation will be documented in
a POLREP which will be distributed to all RRT members. The initial
activation notice may be provided by telephone, but will be confirmed
in writing.
Full: Notice to ail RRT members {with the exception of representatives of
non-affected States) that their services are requested in response to a
Appendix B-3-1
€ 1C i
-------
pollution incident. The activation notice will specify the services
being requested from each RRT member. The services of some
members may be limited to advising the OSC on general matters. The
initial activation notice may be provided by telephone, but shall be
confirmed in writing.
The RRT can be deactivated by the Chair, when the Chair determines that the OSC
no longer requires RRT assistance. The time of deactivation shall be included in a
POLREP.
Appendix B-3-2
0102
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APPENDIX B-4
POLLUTION REPORTS
The following are examples of the information to include and the format to use for
the reports discussed in Part III of Annex B - Reporting Procedures. Tabs are listed
below.
TABS
B4-A. DAMAGE ASSESSMENT/TRACKING FORM
B4-B. POLREPS
B4-C. COST DOCUMENTATION
B4-D. OSC REPORT/AFTER ACTION REPORT
B4-E. DEBRIEFING/CRITIQUE
Appendix B-4-1
! i
\ i
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TAB B4-A.
DAMAGE ASSESSMENT/RESPONSE TRACKING FORM
PRIORITY;
RECORDED BY: ASSIGNED TO:_
DATE: COMPLETE:
TIME: PENDING:
INCIDENT NAME:
DESCRIPTION OF REPORTED CONCERN:
LOCATION:
CONTACT NAME/AFFILIATION/PHONE NUMBER:
INSTRUCTIONS TO RESPONDER:
****~~¦*#~**####~##**~###~*######~**#~#~###**####*~*~*##~#~~~*
RESPONDER'S OBSERVATIONS:
RECOMMENDED ACTION:
ACTION TAKEN:
Appendix B-4-2
010 4
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TAB B4-B.
POLLUTION REPORTS (POLREPS)
The following is a sample format for an OSC Report or After Action Report.
Comments are provided in boxes to assist with writing the report.
U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION REPORT
1. HEADING
Date:
From:
To:
Site Name and Location:
POLREP #.
II. BACKGROUND
Site No: Delivery Order No or FPN:
Response Authority: NPL Status:
State Notification: Start Date:
Demobilization Date: Completion Date:
Status of Action Memorandum:
FOR PROGRESS POLREPS: If you do not wish to repeat the basic site description from the initial
Polrep, you may delete Section I! "Site Information" up to Section IV "Response information". You
may wish to add a note referring the reader to POLREP #1 for further site background.
III. SITE INFORMATION
A. Incident Category:
B. Site Description:
For Progress, Special, and Final POLREPS: If this is not also an initial POLREP, the entire Site
information Section (III) should be a short summary and/or a sentence referring the reader to
POLREP #1. •¦¦¦¦
For Initial POLREPS: Include acreage and ownership in a description of the setting. Describe the
area {e.g., residential, urban, commercial) and estimate the number of people threatened {i.e.,
population within a one-mile radius of the site).
Appendix B-4-3
-------
Site description:
Appendix B-4-4
-------
Discuss past and present site activities.
Describe the threat to human healtfv or the environment posed by the site, if the threat stemmed
from a discrete Incident or release, include the date and what ensued.
2. Description of threat:
Briefly discuss the results of the preliminary assessment {PA}.
C. Preliminary Assessment Results:
IV. RESPONSE INFORMATION
A. Situation
For initial PQLREP: Describewhat response actions have already beeninitiated, including the
preparation of an Action Memorandum, whether OSC invoked the $50K response authority, any
actual site mobilization and response actions taken, and community relations.
For progress or final POLREPS: Describe response activities undertaken since the last POLREP,
including mobilization, sampling and analysis, waste containment and cleanup activities, and
community relations activities.
For special POLREPS; Describe the incident or change in circumstances which necessitated a
special POLREP. Indicate what actions have been taken in response to the incident or change in
circumstances.^
1. Current situation:
For Initial POLREP: Describe what response actions have already been initiated, including the
preparation of an Action Memorandum, whether OSC invoked the $50K response authority, any
actual site mobilization and response actions taken, and community relations.
For progress or final POLREPS: Describe response activities undertaken since the last POLREP,
including mobilization, sampling and analysis, waste containment and cleanup activities, and
community relations activities.
For special POLREPS: Describe the incident or change ki circumstances which necessitated a
special POUREP. Indicate what actions have been taken in response to the incident or change in
circumstances..
2. Response actions to date:
Appendix B-4-5
010
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Discuss State and/or other local agency involvement, include any request for USEPA assistance;
any State or local agency cooperation in assessing the incident and threats; and any "first
responder" or other actions taken by State or other agencies to protect public health and the
environment. Include whether State or other agency personnel remain at the site.
Indicate what enforcement actions {including PRP search, notification letters, administrative orders,
etc.) have been initiated by USEPA or the State. " -
3. Enforcement:
Discuss the overall planned response actions. 1
B. Pi*TiTiAfl Response Actions
C. Next Steps
For Initial POiAEF: Describe plans for response activities. Include site
mobilization, saapling and other cleanup activities. Also describe any
planned enforcement activities including PRP searches.
For progress and final POLRBPS: Describe plansfor ongoing response
activity. Include waste analysis, containment, and cleanup. Also describe
any planned enforcement activities. ¦ : ¦ .. . -V'* ": ¦
D. Kev Issues
For all POIiRBFS: Identify any problem areas or issues of concern.
For - final POIiRKP s, Results Achieved: State how - you: achieved -the : obj ectives
set forth for the response action. Specifically address any wastes
remaining on the site, including those which are contained. Document how
threats to human health and the environment have been reduced or
eliminated.
DiscusB the status of the OSC Report and the expected completion date. If
applicable, indicate any future site actions
-------
Provide detailed, current cost information front the site'e cost
documentation. Note ceiling for contractors, if such ceilings are
maintained. Cost information may be entered in the table below.
Appendix B-4-7
-------
tg-K-t-T-atnnral Costs;
• Regional Allowance Costs:
Total Cleanup Contractor Costs
IAGs
Cooperative Agreements
Other Extramural Costs not Funded
From the Reerional Allowance:
TAT
NCLP
REAC
Subtotal, Extramural Costs
TOTAL, EXTRAMURAL COSTS
Tnf-yjuitii.ral Costs:
Direct Costs (Region, HQ, ERT)
Intramural Indirect Costs
TOTAL, INTRAMURAL COSTS
TOTAL SITE COST
Project Ceiling
Project Funds Remaining (percentage)
VI. DISPOSITION OF WASTES
Using the matrix below, list the waste streams identified, and note the
medium and quantity. For each waste stream, indicate the disposition
-------
TAB B4-C.
311(b)(3) CASE DOCUMENTATION REPORTS
Case documentation reports are used when a release violates the Clean Water Act
Section 311(b)(3). The Incident OSC is responsible for ensuring the accurate
documentation of the circumstances of an oil spill and its subsequent cleanup
operation. The OSC can request that the Enforcement Specialist be at the spill site
to assist with the case documentation and preparation.
Guidelines for preparing the report are included as Attachment VI in the USEPA Region
IV ERRB's Oil Spill Enforcement Guidelines (OSEG). Copies can be obtained from the
ERRB Enforcement Specialist.
A complete documentation package consists of the following, where applicable. Each
item is discussed in the OSEG.
t. Case Documentation Cover Sheet
2. Incident Report Form for the spill
3. Completed oil response checklist with applicable attachments.
4. Any Notices of Federal Interest or Assumption
5. OSC logbook
6. Photographs
7. Analytical data
8. Incident summary report
9. A completed CWA Section 308 questionnaire from the responsible party.
10. A copy of the SPCC plan
11. A copy of the Facility Response Plan
12. Any Letter of Deficiency, Administrative Orders, or Administrative Complaints related
to the spill
13. Copies of Agency correspondence concerning the incident
14. Maps and drawings showing source of the spill and extent of the damage
15. A penalty calculation matrix
16. Any reports by local, state, or other Federal agency documenting damages caused by
the spitl
17. Reports by USEPA, local, state, or other Federal agency documenting prior
deficiencies or violations by the facility
18. ERNS search of facility spill history
19. Table of Witnesses
Appendix B-4-9
0 1 * -S
t a x 1
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TAB B4-D.
OSC REPORT/AFTER ACTION REPORT
The following is a sample format for an OSC Report or After Action Report.
Comments are provided in boxes to assist with writing the report.
FEDERAL ON-SCENE COORDINATOR'S REPORT
Name of Incident Response/Site
Location
Name of OSC
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Executive Summary
SITE:
LOCATION:
PROJECT DATES:
In this Executive Summary, provide a summary of the incident which includes a brief site history,
the nature of the contaminants on site, and any PRP information.
INCIDENT DESCRIPTION:
Provide a summary of the mitigative actions taken, and the method of disposal that was followed.
ACTIONS:
Add the OSC's name. Region, and location (city and state). Sign the document in the space
provided.
(name), OSC
USEPA, Region 4
Atlanta, Georgia
Appendix B-4-10
0112
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I. SUMMARY OF EVENTS:
A. Site Conditions and Background:
Describe the history of the incident or release
-------
Describe chronologically the details of any threat abatement actions taken under CERCLA or under
Section 31 He) or
-------
A. Actions Taken bv PRPs:
Describe any role played or assistance provided by slate or local authorities. Describe their actions
as first responders, and Indicate whether the state made arrangements for post-response site
control.
B. Actions bv State and Local Agencies:
Describe any roie played or technical assistance providedby the NRT, RRT, USCG, ATSDR, FEMA,
or individual agencies in the planning and conductingthe response.
C. Actions Taken bv Federal Aoencies and Special Teams:
Review the work performed by any contractors. Indicate whether all tasks assigned were
completed and equipment or personnel were providedwrMin acceptable time frames. Indicate
whether health and safety protocolsand environmental Jawsand regulations were followed.
Indicate whether work performed by volunteers was valuable to or a liability of the response action.
D. Actions Taken bv Contractors. Private Groups, and Volunteers:
III. DIFFICULTIES ENCOUNTERED
Evaluate the efficiency of the response action. List technical, naturally occurring, and
uncontrollable items that adversely affected the removal action.
A. Items That Affected the Response:
Assess the quality and efficiency of communication and coordination efforts among all parties
involved in the response action. Cite examples that hindered or disrupt the response action.
B. Issues of Intergovernmental Coordination:
Indicate those policies and regulations that in any way effected the smooth and expeditious
progression of the response action, and the manner in which they effected the response.
C. Difficulties Interpreting. Complying With, or implementing Policies and Regulations:
Appendix B-4-13
1 1 * r.
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IV. RECOMMENDATIONS
Examine the cause of the incident, and determine what actionte) could have prevented ft. Provide
recommendations for how USEPA, or other Federal or state agencies could act to prevent similar
occurrences.
A. Means to Prevent a Recurrence of the Discharge or Release:
Provide recommendations to address the difficulties encountered. Detail what went well in the
response action and provide recommendations so that other OSCs can take advantage of your
experiences."
B. Means to Improve Response Actions:
indicate those regulation or policies that hinder tatherthan promote the efficient, timely anil safe
completion of response actions. State the rranner in whch tney ntnaer ;operations, and provide
recommendations for their revision.
C. Proposals for Changes in Regulations and Response Plans:
Appendix B-4-14
0118
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TAB B4-E.
DEBRIEFING/CRITIQUE
CURRENTLY BEING DEVELOPED
Appendix B-4-15
-------
RESPONSE STRATEGIES (for Releases of Oil)
PURPOSE and SCOPE: The purpose of this annex is to outline strategies for
responding to spills within the Region IV area. The diversity of spill scenarios
makes it impossible to predict specific actions for every release. This annex will
not identify an optimum spill response option, but provide options for selection to
satisfy the existing situation. Unexpected factors occur in every response which
complicate even the best of strategies. Therefore, it is the responsibility of the
Incident OSC to continually assess a spill situation so that the Agency's priorities
are met and resources used effectively. The information contained within this
Annex is designed to assist the Incident OSC in making response decisions that are
consistent with the following priorities:
RESPONSE PRIORITIES
Priority 1, Protect Human Life and Health
A. Worker/Responder Safety
* Fire and explosion threat
* OSHA requirements
* Boating and water safety
B. Public Safety
* Protection of drinking water intakes
* Alternate water supplies
* Air monitoring, if burning occurs
* Evacuation
Priority 2. Reduce Overall Impact of Spill
A. Control Spill Source
B. Implement Prevention Measures:
* Physical containment
* Burning
* Dispersants
* Bioremediation
C. Monitor
Priority 3. Protect Environmentally Sensitive/Critical Habitats
A. Identify Sensitive Areas
B. Develop Protection Strategy
C. Conduct Wildlife Rescue
Priority 4. Protect Economically Sensitive Areas
Priority 5. Cleanup Spilled Material
A. Physical Recovery
B. Shoreline Countermeasures
Priority 6. Restoration
0118
-------
RESPONSIBILITIES: It is up to the Incident OSC to assess the incident
situation and determine what strategy to undertake to comply with the Region's
strategies. The Incident OSC must also coordinate all activities with the Logistics
OSC, the Cleanup Teams and the Advanced Teams to ensure that the priorities are
fully understood and are being followed.
PROCEDURES FOR DEVELOPING A STRATEGY:
STEP 1. M3ATHER INFORMATION
* Ask the following types of questions before developing a response strategy.
* What is the exact spill location?
* How much oil was released? What type?
* Where is oil going? How fast?
* What are the dissipation characteristics?
* What is located downstream?
* What resources are at risk?
* What are the on-scene weather conditions?
* What are future weather conditions?
* What circumstances require special attention?
* Is there a fire or explosion threat?
* What are the public safety hazards?
* What actions are being taken so far?
* What other actions need to be taken immediately?
* What equipment is available?
* How long will it take to get to spill site?
* What approval is needed for a proposed response method?
* Is there adequate access for equipment?
* Where can collected material be stored and disposed?
* How can the available resources be utilized to meet the agency's priorities?
STEP 2. PRE-RESPONSE ASSESSMENT
* Determine the level of response needed.
* Begin filling positions to support the chosen level.
* Form the cleanup and advance teams, and arrange for logistics.
* Deploy the teams to gather information needed to make further decisions.
* Establish the operations centers.
* Contact appropriate persons to arrange for funding of the response.
Steps 3, 4 and 5 continued on next page.
C-2
Oil
-------
STEP 3. INITIAL ON-SITE ASSESSMENT
* Determine priorities and specific strategies for each area at risk.
* Coordinate between the Incident Operations Center and the field teams.
Communication is vitai.
* Determine the Public Health issues.
* Notify the necessary officials of any impact to drinking water or industrial
intakes.
* Locate provisions for an alternate water supply.
* Review Response Operations Guidelines in this Annex.
STEP 4. MOBILIZATION LOGISTICS
* Identify sources for additional personnel and equipment. Mobilize to the site
as needed.
* Ensure that personnel are properly trained, and health and safety issues are
addressed.
* Contact the Natural Resources Trustees.
STEP 5. ON-SITE LOGISTICS
* Arrange additional resources as needed. (I.e. food, lodging, additional
clothing, transportation, communications, air support).
* Develop and Implement Site Safety Plan.
C-3
612 0
-------
GUIDELINES FOR RESPONSE OPERATIONS
GENERAL GUIDELINES
* Obtain all necessary concurrence from FtRT and any other relevant agencies before using any
treatment/response method.
* Become familiar and comply with approved methods, work plans, advisories and special
instructions prior to implementation.
* Minimize the potential to recontamkiate areas or attract wildlife by removing oil trapped in booms
and trash around site on a daily basis.
* Notify appropriate resource agencies of any reports of dead fish, mammals, and birds found
during the response.
* Do not approach, feed or harass any wild animals or birds. Only trained personnel should conduct
wildlife rescues. Report all incidents of oiled or stranded birds and animals to the appropriate
agencies.
BIOLOGICAL RESOURCES
* Contact Natural Resource Trustees.
* Avoid treatment methods that removal large numbers of indigenous vegetation, invertebrates or
microorganisms from shorelines and marshes.
* Boom off sensitive areas (wetlands, marshes, creeks) adjacent to areas where response
operations are taking place.
* Remove all signs of human activity when operations are over.
CULTURAL RESOURCES
IMMEDIATELY take the following steps If cultural materials (fossils, archaeological, or historical) are
discovered during response operations:
* Do not disturb, remove or alter archaeological or historical sites, facilities or artifacts. Mark off
area with flagging tape.
* Stop cleanup activities in the surrounding area.
* Inform the State representative to the RRT.
* If a significant site or burial grounds are uncovered, contact the landowner and immediately notify
the state archaeological society representative or state historic preservation officer.
i
C-4
0121
-------
HrruvuiA u- i.
TYPES OF OIL
There are many complicating fact on during an oil response. OUa have different physical properties depending upon where it comes from
and whether it hae been processed into a ussabte end product. These physical and chemical differences mean that teams planning for or
row ponding to a release of oil must use the approach that is specifioaJly tailored to the particular properties of the kind of oil releassd. For
example, some types of spilled oil may respond well to the introduction of nutrients to stimulate biodegradstion by indigenous
microorganisms; other spilled products may require the introduction of new biodegrading species
CRUDE OB.
OIL
CHARACTERISTICS
SPECIAL FEATURES
CLASS A: Light, volatile
(highest quality
light erudes)
- Highly fluid
- Spreads rapidly
• Strong odor
- High evaporation rate
¦ FLAMMABLE
¦ Non-adhesive
¦ Flushes with water
¦ Highly toxic
CLASS B: Non-sticky oils
(medium fuel oils and
paraffin baaed ois)
- Waxy/oily fset
- Adhesive to aurfacaa
¦ Removes w/ vigorous flushing
¦ Lses toxic than Claas A
CLASS C: Heavy, sticky oils
(residual fuel oils and
medium to heavy crude)
- Viscous, sticky
- Brown/black color
- Density near water
- Sinks as voletizss
¦ Rushing doss not remove
- Ooea not penetrate surfaces
- Low toxicity
- Can smother/drown wildlife
CLASS D: Non-fluid oils
(residual oils, heavy crude
oils, paraffin oils,
weathered oils)
- Black/dark brown
- Relatively non-toxic
- Ooea not penetrate surface*
- If heated, may matt and coot
surface
REFMED OIL PRODUCTS
OIL
GASOLINE
CHARACTERISTICS
- Lightweight flows easily,
may evaporate completely
SPECIAL FEATURES
- FIRE & EXPLOSIVE RISK
- Highly volatfle
- More toxic than crude oil
- Amenable to biodegradstion
KEROSENE
' Lightweight,
flows/spreads rapidly,
evaporatee quickly
' Easily dispersed
• Persistent in the environment
No. 2 Fuel Oil
- Lightweight,
flowe/spreade rapidly,
relatively non-volatile
• Eaaily dispersed
• Non-persistent in environment
• Does not form emulsions
No. 4 FUEL OIL
¦ Medium weight,
flows easily
- Easily dispersed w/ prompt treatment
- Low volatilization
- Moderate flash point
• Persist partially in environment
No. 5 FUEL OIL
(Bunker B)
- Medium to heavy weight
- Low volatilization
- Moderate flash point
• Difficult to disperse
No. 6 FUEL OIL - Heavy weight. - Not prone to dissolve
(Bunker C) difficult to pump, requiree heat - Difficult to disperse
heavier than water • Forme tar bads, lumps, & emulsion
- Low volatilization
- Low flash point, > 150*F
SPECIAL OILS
GAS OIL: A liquid petroleum distillate derived in the refining process that is composed mainly of volatile hydrocarbons and hydrogen. Ga
oils are used as components for domestic heating fuels, are blended with residual fractions to reduce their viscosity to make acceptable
heavy fuel oils, snd can refined further to make gaeoline. Gas oil, which hae a viscosity and boiling range between keroeene and
lubricating oil. ranges from a light to heavy weight material and may vary in terms of its volatility, flaah point, and persistence in the
environment.
LUBRICATING OIL: A medium weight material that flows easily and is eaaily dispersed if treated promptly. It hae a low volatility and
moderate flaah point, but is fairly persistent in the environment.
Appendix C-1-1
0 1 2
-------
iirr uiil/i/v
TYPES OF ENVIRONMENTS IMPACTED
Freshwater Marshes/Swamps
Description:
* Marshes characterized by soft-bodied, non-persistent, herbaceous vegetation, such as grasses.
Swamps have dense stands of water tolerant shrubs and trees.
* High degree of species diversity. May harbor sensitive or endangered species.
* Breeding and nursery areas for many species.
* Sediments usually consist of organic soils with a soupy consistency.
* Foot travel very difficult.
Predicted Impact:
* Minimal flushing and organic soils allow oil to remain in environment.
* Season is important - dormant vegetation least sensitive; blooming and budding plants most
sensitive.
* High mortality rate - especially for reptiles, amphibians and crustaceans.
* Trace contamination can impact water supplies.
Suggested Actions:
* High-priority areas require the use of spill protection devices to minimize impact (i.e.
deflection booms, skimmers)
* Allow lightly covered areas to recover naturally.
* Avoid activities that mix oil into organic soils and sediments.
* Conduct manual pickup from boats and floating platforms.
* Use the least intrusive cleanup methods. A no-action alternative may be appropriate to
minimize the environmental impact.
* Quick flushing and removal of oil while still fresh can reduce long-term impacts.
Vegetated Bank
Description:
* Low banks with grasses or steeper banks with trees.
* Located in fresh or brackish water.
* Contain a variety of plant species.
Predicted Impact:
* Heavy oil concentrations penetrate areas and coat plant and ground surfaces. Impact can be
severe.
* Oil can persist for months.
* Water supplies can be impacted through trace contamination.
Suggested Actions:
* Use caution when cleaning. Supervise and minimize plant cutting, if conducted.
* A no-action alternative may be appropriate to minimize environmental impact.
* Cleanup usually unnecessary for light coatings; heavier accumulations may require sediment
surface removal to allow new growth.
* Low-pressure spraying may aid removal.
Appendix C-2-1
-------
Sand Beaches
Description;
* Fine/coarse sand and gravel beaches. Typically found along coastal areas and along
sandbars in inland rivers.
* Sloping profiles vary from gentle to steep.
* Species density and diversity low along coarse sand or gravel beaches.
Predicted Impact:
* Heavy accumulations of oil can cover entire beach surface.
* Oil can penetrate from 15 cm to 60 cm deep.
* Organisms living along beach killed through smothering or by oil in the water column.
Reduces food sources for birds and other animals.
* Birds and animals may become oil coated.
Suggested Actions:
* Fine sand beaches are easier to clean.
* Remove oil above the swash zone after all oil has come ashore.
* Minimize sand removal to prevent erosion. Manual cleanup more efficient. Heavy equipment
may remove excess sand.
* Limit activity around sensitive areas such as dunes.
* Prevent grinding of oil deeper into beach by limiting activity in heavily contaminated areas.
Riprap Structures
Description:
* Cobble to boulder-sized rocks used for shoreline protection.
* Organisms and plant life can be plentiful and varied.
Predicted Impact:
* Deep penetration of oil between boulders. If left, oil can asphaitize.
* Fauna and flora may be killed by oil.
Suggested Actions:
* Remove all oiled debris.
* Use sorbents to remove oil in crevices.
* May remove and replace heavily oiled riprap to prevent chronic sheening.
Bluffs
Description:
* Usually found along eroding river banks.
* Composed of mixed grain sizes (from silt to gravel).
* Biological activity usually low.
Predicted Impact:
* Oil forms band along top of water line. Can penetrate into sandy sediments.
* Wave or current action can flush off oil within days or weeks.
Appendix C-2-2
e 12 4
-------
* Cleanup usually not necessary due to short residence time.
* Manual labor can be used to scrap oil from surfaces.
* Avoid removing sediments.
* Avoid mechanical cleanup (limited access and steep slopes).
Wall; Piers, and Docks
Description:
* Common in developed areas to protect or facilitate access in residential and industrial
locations.
* Constructed of concrete, stone, wood or metal.
* Mussels, shellfish, and algae often found attached to structures.
Predicted Impact:
* Oil percolates between joints and coats surfaces.
* Biota damaged or killed under heavy accumulations.
Suggested Actions:
* High-pressure spraying may remove oil, prepare substrate for recolonization of fauna/flora,
minimize aesthetic damage and chronic leaching of oil from structure.
Appendix C-2-3
012;;
-------
APPENDIX C-3.
METHODS TO REDUCE OVERALL IMPACT
TAB C-3a. PHYSICAL CONTAINMENT
Includes booms, by-pass dams, overflow and underflow dams, diversion berms, permeable barriers
ADVANTAGES:
* Physically deflects movement of spfll; collects slick for recovery /burning.
* Can be constructed of on-site materials; barriers or berms,
* Can be used to protect economic or ecologically sensitive areas.
* Pre-spill booming strategies can be developed, equipment pre-staged.
DISADVANTAGES:
* Requires significant time to put in place.
* There Is not one universal boom or barrier (use depends on type of pollutant, wind, current, shore topography).
* Use limited by availability of deployment/recovery areas and anchoring conditions.
* Link-up compatibility may be difficult with different types of booms.
* Currents in excess of 0.7 knots perpendicular to boom will result in entrapment?. Effect independent of depth of skirt.
* Wave height and frequency must be taken Into account when selecting boom flexibility. Incorrect matching may result in splash over.
* Barriers/ dams time consuming to build; equipment dependent.
C,*5
)¦*»»>>
JS5
©•>
Appendix C-3-1
-------
TAB C-3b. PHYSICAL REMOVAL:
Skimmers (suction, floating weirs, oleophlllic disks, drums or belts, hydrodynamlc planes, and vortex or cyclonic skimmersL
ADVANTAGES:
* Physically removes oil from the environment.
* Works with all kinds of oil states; even emulsified.
* Higher recovery rate than sorbents.
DISADVANTAGES:
* Vortex or cyclonic skimmers and oleophillic disks not effective on highly viscous oil.
* Works on principle that oil floats on water. High water uptake on very thin oil layers increases volume of waste stream.
* Loss of efficiency in high tidal or current environments.
* Limited by storage.
* High amount of monitoring required during operation.
* Low tow speeds; effectiveness limited by amount of debris present in water.
Common types of skimmers:
Band (or Rope) Skimmer:
Uses oleophilic material such as polypropylene. Oil collected by drawing a continuous rotating band of material through the slick. Adhered oil is
wrung from the band by a squeeze roller and collected In an oil sump. High efficiency in calm waters.
Use an oleophilic material belt mounted on the front of a small vessel. The belt pushes the oil below the waterline. Oil carried up the belt is
recovered at the top of the system by a squeeze belt or scraper blade and then pumped into a storage container. Not good in shallow waters or
tight areas.
-------
TAB C-3c. CHEMICAL OIL STABILIZERS
Solid Forming Agent (solidify or gelatinize oil to keep it from spreading or escaping and causing re-oiling elsewhere, Eiastoi is an example of an
oil stabilizing agent.}
ADVANTAGES:
* Causes oil to change from a liquid state to a "jelly" like substance that does not react with the environment.
* Lowers explosion vapors.
* Enhances polymerization of hydrocarbon molecules when applied by liquid spray or sprinkling of dry chemical in the proper dosage.
* May reduce solubility of the more toxic short chain and cyclic hydrocarbons by locking them into the polymer.
* May enhance recovery.
DISADVANTAGES:
* MAY TAKE TIME TO GET RRT CONCURRENCE PRIOR TO APPLICATION
* Reacts with any hydrocarbon; oil, containment boom, weeds, etc.
* Unknown consequences when in contact with animal oil.
* Not suitable for vegetated shorelines, seawalls or riprap. Congealed oil sticks .to vegetation and remains In crevices making removal
extremely difficult.
* Do not use if marine mammals, birds or other wildlife may come Into contact with congealed oil.
* Increases smothering of sessile and interstitial organisms.
* May increase residence time of oil In environment by decreasing evaporation, dissipation and biodegradatlon rates.
TAB C-3d. DE-EMULSIFYING AGENTS:
De-watering agent (used to break up or prevent water-ln-oil emulsions (generally a surfacantl}
ADVANTAGES:
* Separates oil and water from recovered emulsions (50% water to oil)
* Potential use in field to make emulsions burnable in place
DISADVANTAGES:
^ * NONE on NCP Product Schedule, Cannot be used in U.S. waters
|—k
l-X>
CO
Appendix C-3-3
-------
TAB C-3e. DISPERSANTS
Chemical agents that emulsify, disperse or solubllize oil Into the water column or promote the surface spreading of oil slick to facilitate dispersal
of the oil into the water column and enhance biodegradation. (consult NCP Product Schedule)
ADVANTAGES:
* Reduces amount of slick able to reach the shoreline.
* Most effective if applied to slick within first 24 hours after spill.
* Removal/disposal reduced.
* Dispersants have been Improved to be less toxic than in past.
DISADVANTAGES:
* NOT USED IN INLAND WATERS.
* MAY REQUIRE TIME TO GET RRT CONCURRENCE. CONSULT REGION IV DISPERSENT USE PLAN.
* Water column must be at least 30 feet deep.
* Toxicity problems may result from increasing uptake of oil in biota.
* Little field data on effectiveness and toxicity impacts.
* Lots of unknowns.
* Difficulties tracking the underwater plume.
* Difficulties obtaining equipment.
TAB C-3f. SURFACE COLLECTING AGENTS (or Surface Washing Agents):
Land or shoreline dispersant
ADVANTAGES:
* Acts as a detergent to reduce adhesion of oil to substrate.
* Enhances removal of oil.
* Lowers water temperatures needed for washing.
DISADVANTAGES:
* Washing agents remove the oil from the surface of shoreline, but allow it to coalesce on the water surface.
C£> * Method may drive oil into sediment pores.
* Potential toxicity problems when adding chemicals and making oil more available to the biota (surface weathering may require a
CO "potent" product).
-------
TAB C-3g. IN-SITU BURNING
Removal by fire fdisposal of oil on the water through Ignitionf
ADVANTAGES:
* Works on thin films (down to 2 mm.)
* On films of 100 mm (4 inches) or more, burning is 98-99% effective,
* Disposal rates of 100 - 30,000 gals/min (10,000 ft2 to 1 square mile burn).
* Easy to Ignite If oil is a proper thickness (must be at least 2 mm thick).
DISADVANTAGES:
* MAY TAKE TIME TO GET RRT CONCURRENCE, (Consult Region IV In-Situ Burn Plan).
* Can have a highly negative Impact In small rivers and Inland lakes.
* Requires specialized booming.
* 3M boom ($250 - $300 per foot, good to -40°F to +2,000°F).
* Smoke plume can be visually disturbing. May create a public outcry.
* Potential toxicity of plume still being Investigated, contains polycycllc aromatic hydrocarbons (PAHs);(A 100,000 gallon spill when
burned equals the amount of smoke from 50,000 wood stoves).
* Air quality permits may be required.
* Modeling and pre-burn weather data needed.
* Combustion products may travel great distances before falling to earth.
C 5
CZ>
Appendix C-3-5
-------
TAB C-3h. BIOREMEDIATION
A. Nutrient Enhancement:
Enhancement of microbial metabolism of organic contaminants through addition of nutrients and oxygen to the contaminated environment.
Results In breakdown and detoxification of contaminants. (Consult NCP Product Schedule) Also, contact RRT to determine if concurrence is
necessary before application.
ADVANTAGES:
* Does not require addition of non-native microorganisms. Works with natural populations.
* Works on a wide variety of contaminants.
* Fertilizers are not typically harmful to nearshore environments.
* Can be used for both surface oil and subsurface oil spills.
DISADVANTAGES:
* Potential for algae blooms, however little evidence to support this.
* Soils with low permeability difficult to treat. Increases time for nutrients to reach microorganisms.
* Contaminant degradation impaired by nutrient overloading, toxicity of nutrients and oxygen depletion.
* May take weeks or years to completely degrade contaminants.
B. Bacterial Addition:
Deliberate introduction of non-indigenous microbiological cultures or enzymes into an oV discharge for the specific purpose of enhancing
biodegradation to mitigate the effects of the discharge, (consult NCP Product Schedule)
ADVANTAGES:
* Have the potential to begin degrading materials right away without an acclimation time.
* Can work with natural populations of microorganisms.
DISADVANTAGES:
•
MAY TAKE TIME TO GET RRT CONCURRENCE.
o
L , , 1
•
Still highly experimental. No solid evidence to support effectiveness.
•
Carrier may be highly toxic.
C3
«
Granular forms are viewed by some as a problem.
•
Natural species may be just as effective at a much lower cost.
-------
CLEAN UP TECHNOLOGIES
The following table presents a number of alternatives for cleaning up oil in the environment, primarily along shorelines. Before
undertaking any of the these methods, the Incident OSC should consult with the Region IV Regional Response Team along wit
State and Local officials. The information listed was adapted from EPA's Region III Shoreline Countermeasures Manual and thi
American Petroleum Institute's Inland Oil Spill Manual.
ACTION
DESCRIPTION
WHEN TO USE
BIOLOGICAL
CONSTRAINTS
ENVIRONMENTAL
EFFECTS
No Action
No Action is taken.
When shoreline extremely remote,
Inaccessible, or cleanup will do more
damage or an effective method is not
available.
Not for areas with high
number of mobile animals.
Same impact as oil.
Manual Removal
Remove surface oil by manual
means and placed in containers
for disposal. No mechanized
equipment used.
For areas where oil can be easily
removed.
None.
Minimal if surface
disturbance and work
force movement is
limited.
Passive
Collection
Sorbents
Sorbent material placed on oil
surface.
When oil Is viscous and thick enough
to be absorbed.
None. Method can be slow
allowing oil to remain in
critical habitats.
No major effects except If
soaked sorbent materials
are left in environment.
Debris Removal
Manual or mechanical removal of
debris, Including cutting an
removal of oiled logs.
Use on any accessible area.
Especially Important when
contaminated debris could
contaminate other organisms.
None.
None.
Trenching
Dig wells or trenches to the
depth of oil and pump oil out of
well. Best with lighter oils.
Fine grain sand beaches, coarse sand
and gravel beaches where oil has
seeped in and cannot be removed by
manual cleaning.
None.
None.
O
e.3
ls3
Appendix C-4-1
-------
ACTION
DESCRIPTION
WHEN TO USE
BIOLOGICAL
CONSTRAINTS
ENVIRONMENTAL
EFFECTS
Sediment
Removal
Mechanical or manual removal of
sediments. Material disposed of
off-site.
Used on sand, pebble and cobble
beaches where limited amounts of
oiled material have to be removed.
Do not use in areas with erosion
potential. Do not removal sediments
past the depth of oil penetration.
Mechanized equipment
should not be used in areas
adjacent to endangered or
sensitive species.
Maybe detrimental if too
much sediment removed
without replacement.
Cold Water
Flooding
Wash oil from surfaces and
crevices to water's edge for
collection.
Boulder, cobble, gravel, coarse sand
mixed with sediment and rock. Not
applicable to mud, vegetated upland
or steep rocky shorelines. Frequently
used with low or high pressure
washing.
Not appropriate at creek
mouths.
Habitats may be
physically disturbed as
sand and gravel are
mixed. Organisms may
be flushed away.
Cold Water/
Low Pressure
Washing
Remove oil that has adhered to
rocks or man-made structures.
Oil floated to shoreline for pickup
by a skimmer.
Boulder, cobble and rock/
seawall shorelines heavily oiled. Not
appropriate for sedimentary habitats.
Best where adhered oil must be
removed to prevent continuous
release into environment.
Not appropriate for sand,
gravel, mud beaches,
marshes or shorelines where
destruction of biological
communities must be
avoided.
May flush contamination
into other areas.
Increases turbidity in
water.
Cold Water/
High Pressure
Washing
Better for removing adhered oil.
Water pressure up to 100 psi.
Riprap, rock and seawalls. Can be
used to float oil out of crevices.
Not appropriate for sand,
gravel, mud beaches,
marshes or shorelines where
destruction of biological
communities must be
avoided.
Removes many organisms
on surface. May drive oil
deeper or flush into other
environments. Increases
turbidity.
Warm Water/
Moderate to
High Pressure
Washing
Mobilize thick and weathered oil
adhered to rock surfaces prior to
flushing it down shore for
pickup.
Boulder, cobble, and rock/
seawall shorelines that are heavily
oiled. Not appropriate for
sedimentary habitats. Good for
weathered or difficult to remove oil.
Tradeoff between damage
to the biological community
versus damage from leaving
oil in place.
Can kill or remove most
organisms. May flush oil
into other environments.
Increases turbidity.
-------
ACTION
DESCRIPTION
WHEN TO USE
BIOLOGICAL
CONSTRAINTS
ENVIRONMENTAL
EFFECTS
Hot Water
Pressure
Washing
Dislodge trapped oil from
inaccessible locations and
surfaces not amenable to
mechanical removal. Requires
extensive equipment (water
heat - 170°F). Vacuuming
necessary to remove oil flowing
from rocks and soil.
Not applicable to sandy beaches,
marshes or where difficult to place
equipment.
Must be careful not remove
all attached organisms from
surfaces. Decreases
biodegredation potential.
Has a highly negative
impact on most
environments. Possibility
of driving oil further into
substrate.
Slurry Sana
Blasting
Use sandblasting equipment to
remove heavy residual oil from
solid substrates.
Seawalls and riprap. Equipment can
be operated from boat or land.
Not to be used in areas with
high biological abundance on
the shoreline.
Possible destruction or
smothering of organisms.
Vacuum
Use suction head, hose, pump
and storage tank to recover free
oil from the water surface.
Use for large volumes of free oil. Can
be used on any shoreline if
accessible.
Do not use in areas where
foot traffic and equipment
may harm organisms.
Minimal impact if done
correctly.
Shoreline
Removal,
Cleansing and
Replacement
Remove and clean oiled
substrata before returning it to
the excavated area. Cleansing
includes hot water wash or
physical agitation with a
cleansing solution.
Sand, pebble, gravel, etc.
Applicable where permanent removal
of sediment Is undesired. Equipment
must be close to excavation area to
reduce transport problems. Cleaning
solutions must be properly disposed.
Typically unacceptable in
spawning areas. Almost all
life will be removed from
area. Replaced material
must be free of oil and toxic
substances.
May be detrimental if
excessive substrate Is not
replaced. Very large
equipment causes
environmental disruption.
Could be negative Impact
if cleaning solution not
properly disposed.
Cutting
Vegetation
Manual cutting of oiled
vegetation using weed eaters
and removal of cut material with
rakes. Cut vegetation is
Immediately bagged for disposal.
When risk of oiled vegetation
contaminating wildlife is greater than
the value of the vegetation that is to
be cut, and there Isn't a less
destructive method.
Prevent forcing of oil into
sediments and
contaminating the root
structures.
Can be a total loss of
habitat for some animals.
Erosion may occur if
vegetation does not grow
back.
CT5
C.£
Appendix C-4-3
-------
APPENDIX C-5.
NATIONAL PRODUCT SCHEDULE
Section 300.905, Subpart J of the NCP establishes the NCP Product Schedule
which contains those dispersants, other chemicals and biological products that
may be authorized for use on oil spills. Also, presented in Section 300.905 are the
procedures for obtaining authorization for the use of items on the NCP Product
Schedule. A copy of the NCP Product Schedule is located in the EPA Region IV
Response Center located in Atlanta, Georgia.
Appendix C-5-1
013S
-------
ANNEX D
REGIONAL RESPONSE RESOURCES
PURPOSE: Immediate action to a release is critical for minimizing the impacts to
people and the environment. A key part of any action is having the appropriate
response resources (i.e. personnel, equipment) available and at the scene as
quickly as possible. Pre-planning and identification of response needs and
resources facilitates the response and saves valuable time that would normally be
lost by hunting around for the required resources. The information contained in
this Annex is intended to be used to direct cleanup operations so that the
necessary resources reach the scene of a response in a quick and timely manner.
The Incident OSC, with assistance from the Logistics OSC, should use the
information to locate and arrange for the necessary response resources prior to
their use. It is the goal of this Annex to allow the Incident OSC to bring to bare all
the necessary response materials and equipment to a spill response to ensure an
efficient and effective cleanup operation.
SCOPE: The purpose of this Annex is to provide the Incident OSC with a listing
of the resources found through out Region IV which can be applied when
responding to an oil spill. The list provide in this Annex are to be used by the
Incident OSC to direct the proper personnel and materials to a spill in a efficient
and effective manner. This listing provides the best listing of available information.
Other information sources which are known and available to the Incident OSC
should also be utilized to ensure the prompt and successful outcome of a response.
In addition, this Annex covers response contractors which operate in Region IV.
Some of these contractors are based within the Region, and some are based
outside but operate in the Region. The tabs and appendixes lists BOA contractors,
ERCS contractors, and other competent and capable firms known to the USEPA
and other response authorities of Region IV. Also included are a listing of their
particular types of material and equipment and the areas which they operate.
RESPONSIBILITIES:
A. INCIDENT OSC: It is the responsibility of the Incident OSC to ensure that
arrangements for the procurement of all necessary equipment and the
deployment of the equipment occurs in an appropriate timeframe and in such
a manner that harmfull effects of the spill are minimized. The Incident OSC
can oversee the procurement of the equipment personally or may designate
a qualified person, primarily the Logistics OSC, to complete this task. The
Incident OSC shall use the information contained in this Annex to locate and
secure all necessary equipment that might be needed to cleanup the spill.
This is not limited to the emergency response equipment, but also includes
containment and transport equipment which might be needed in later stages
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of the response. Finally, it is the responsibility of the Incident OSC to
oversee the cleanup operations and make the final decisions on the types of
equipment employed in the response and to ensure their proper deployment.
LOGISTICS OSC: The Logistics OSC coordinates with the Incident OSC
and the Clean up Teams and Advance Teams. When tasked by the Incident
OSC, the Logistics OSC shall conduct the activities necessary to identify,
obtain and deploy the resources that are needed by the field teams. The
Logistics OSC is also responsible for ensuring that problems with resources
are solved quickly and effectively.
1. CLEANUP TEAM LEADER(S): The Cleanup Team Leader(s)
coordinates with the Logistics OSC or Incident OSC to correctly and
effectively identify needs and deploy response equipment. Activities include
but are not limited to the following tasks:
* Monitor contractor's personnel and equipment;
* Oversee cleanup operations to ensure that all the appropriate
measures are implemented properly;
* Maintain documentation of equipment use and manhours for cost
tracking and recovery;
* Manage and oversee the necessary supply and logistics of needed
equipment on a daily basis; and,
* Supervise response crews on their cleanup tasks and goals.
It is the responsibility of the Cleanup Team Leader to oversee, organize,
manage, and deploy the cleanup teams on a day by day basis. It will be
necessary that this individual prioritize and assign the tasks of the cleanup
crews. The Cleanup Teams Leader will handle the day by day details of the
cleanup operation and will need to have an accurate and reliable assessment
of the spill situation. The Cleanup Team leader shall be familiar with all the
equipment at hand and should refer to the information in this Annex to
requisition any additional equipment.
2. ADVANCE TEAM LEADER: It is the responsibility of Advance
Team Leader(s) to correctly and effectively survey the areas downstream of
the spill and any other potentially effected areas to provide the Planning
Officer, depending upon the command structure, with accurate information
to plan and stage additional equipment. From the survey, the Advance
Team Leader(s) determine resources needed to contain breakouts of spilled
material and identify any sensitive areas which may need additional
protection measures. As with the Cleanup Team Leader, the Advance Team
Leader communicates and coordinates with the Planning Officer to ensure
that all resources and materials are obtained and deployed. The Advance
Team Leader also locates suitable locations for staging equipment.
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C. MANAGEMENT SUPPORT: Management shall assist in the
coordination of obtaining contractors and equipment, as requested by the
Incident OSC. Management shall work in conjunction with the contracting
officers of the ERCSs contract and other resources to provide the Incident
OSC with requested and required material,
PROCEDURES: The Incident OSC shall, upon arrival, undertake the necessary
actions to assess the extent and severity of the spill. This thorough investigation
of the spill shall be conducted immediately upon arrival at the scene so that
valuable time is not wasted and the effects of the spill are not worsened. From this
investigation, the Incident OSC, with assistance from the Logistics OSC, should
determine what resources are needed to control, contain, and remediate the spill.
Some of the factors which should be taken into account are the type of waterway
the spill has occurred on and the speed and volume of the spill. The Incident OSC
shall also make determinations on the accessibility of the spill to heavy equipment
and/or recovery vessels. Once the initial spill assessment is completed, the
Incident OSC shall ensure that the necessary equipment is located and deployed to
the appropriate locations along the spill site.
If a cleanup response is already underway when the incident OSC arrives on-scene,
either conducted by the discharger and/or State and Local officials, an initial
situation assessment shall be conducted to determine the size and severity of the
spill and determine the adequateness of the spill response. If necessary,
the Incident OSC can augment the resources of the ongoing response with Agency
and RRT resources or, if necessary in very
rare cases, assume the lead in conducting the response. If the Incident OSC
determines that the response undertaken either by the discharger or other agencies
is inadequate, then federal moneys shall be released and contractors shall be
deployed to the scene to begin cleanup operations.
The Incident OSC shall review the information outlined in this Annex to select the
appropriate contractors and resources needed to remediate the effects of the spill.
The Incident OSC shall examine the firms listed in the appendices and select those
firms which have the resources and capabilities needed to confront the spill. Once
the firm or firms have been selected, the Incident OSC will provide the contractor
with the necessary information to respond to the spill and begin operations.
The information provided in this Annex is contained in Appendices and Tabs,
which are outlined in a chart located on the following page.
For specific contracting procedures refer to Annex H on Funding and
Contracting,
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TITLE
Appendix D-l
Aviation Support
Appendix D-2
Basic Ordering Agreements (BOA),
USCG
Tab 1
USCG, Second District
Tab 2
USCG, Fifth District
Tab 3
USCG, Seventh District
Tab 4
USCG, Eighth District
Appendix D-3
Federal Region IV, ERCS Contractors
Appendix D-4
USCG Marine Safety Offices, Region
IV
Appendix D-5
Nongovernment and Private
Organizations
Appendix D-6
Supplemental Response Firms
{The information was lasted updated on 25 August, 1993}
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ANNEX £
COMMUNICATIONS
PURPOSE: This annex outlines operational procedures for establishing
communications for pollution responses. It is designed to develop a
communication system capable of rapid expansion to meet the needs of the
response. Sources of communication support are listed which are available to the
responders.
SCOPE: To provide the appropriate level of communications support, this annex
presents capabilities available for planning, coordination, and management of
communications assets. The different methods of communication will be listed
with location and support requirements for optimum results. The Annex provides
information and mechanisms for supporting agencies to enter the response
communications network. At the time of publication of this plan, communications
equipment continues to be added to the inventory. Equipment currently on-hand is
not fully operational. More equipment is under contract for procurement and
installation. Therefore, no inventory listing is presented.
RESPONSIBILITIES:
A. Emergency Response and Removal Branch (ERRB).
* Provide OSCs and ERRB Staff with communications equipment capable of
performing emergency response deployment tasks.
* Obtain primary radio frequencies for ERRB operations. Arrange for shared or
temporary frequency allocations with Federal/State agencies and state/local
governments.
* Arrange for support from appropriate agencies when communications
requirements exceed in-house equipment capabilities. Options are be:
Federal Emergency Management Agency (FEMA), General Services
Administration (GSA), Department of Defense (DOD), or U. S. Coast Guard
(USCG) Strike Team(s).
* Provide communications equipment training for personnel capable of
maintaining proficiency of using the equipment and knowledge of
procedures.
* Initiate administrative action for Interagency Agreements or Memorandums
of Understanding with supporting agencies for communication equipment
and/or assistance.
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B. Regional Response Center (RRC).
* Ensure communications equipment is operational prior to issuing to the On-
Scene Coordinator (OSC) or field teams.
* Assign and record frequencies allocated to a particular response effort.
Program frequencies into radio(s) before releasing equipment for deployment.
* Maintain a file of agency, state, and local government radio frequencies
available for USEPA use and reference.
* Maintain communications log books or journals throughout each response
event. Documents will become part of the After Action Report and files.
C. Technical Assistance Team (TAT).
* Ensure communications equipment is operational for emergency response
deployment.
* Coordinate with the RRC on frequency assignment and ensure TAT radios
are calibrated properly for deployment.
* Provide communications training and maintain proficiency on the use of
equipment and knowledge of procedures.
D. On-Scene Coordinator (OSC).
* Properly utilize assigned communications assets.
* Advise the RRC when frequency overlap or interference requires changing
frequency assignment.
* Ensure adequate communications equipment is available and operational for
the response event.
PROCEDURES:
1. Communication Flow. Responsibility for providing communication linkage flows
from the highest supervisor level to the lower operating elements or supporting
activities of the response.
Example: ERRB arranges for equipment and establishes procedures for the
Incident OSC; who, in turn passes the overall responsibility to the Logistics
OSC; the Logistics OSC arranges and assigns equipment to the Advance and
Cleanup Teams. The Logistics OSC provides operational communication
information to outside support agencies (active radio frequencies and
telecommunication network numbers).
2. External Communications Support. There are sources for augmentation of
communications available for the response effort. These sources are FEMA, GSA,
DOD, or USCG. Request for support to the controlling agency will be initiated by
the Chief, ERRB directly to the agency or through routine procedures of the
Regional Response Team (RRT).
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3. Federal Emergency Management Agency (FEMA). The FEMA Emergency
Support Capability (FESC) can provide a Mobile Emergency Response Support
(MERS) detachment or a Mobile Air Transportable Telecommunications System
(MATTS) unit for response efforts. The initial request to FESC will be by ERRB.
4. General Services Administration (GSA). A Memorandum of Understanding
exists between USEPA and GSA providing procedures for telecommunications
support by GSA. Support available is radio equipment, antennas, generators, etc.
and is listed in the Other Services portion of the MOU. The MOU is presented in
Annex N of this plan.
5. Miscellaneous.
* Department of Defense and U. S. Army Corps of Engineers. Viable sources of
communications support when "first hours" or immediate support is not
required. The most probable support would be as an augmentation to existing
capabilities for a response effort. In support of a response to this plan, the
request would be through the Regional Response Team. In support of a
Federal Response Plan (Emergency Support Function #10) response will be
requested through the Disaster Field Office staff. For either type response the
limiting factor will be the response time, generally 72 hours or longer.
CAPABILITIES/EQUIPMENT AVAILABLE:
1. MRV System: The Multi-Radio Van (MRV) is the major component of MERS.
The van is designed to provide communications with Federal, State, and local
emergency response elements. Capabilities include:
* Connection with public telephone networks (wire or microwave),
* Line-of-Sight radio and commercial KuBand Satillite operations,
* Radio and telephone "patching" equipment,
* Full range of high, very high, and ultra-high radio equipment,
* A 24 line telephone access panel for commercial operations.
The vehicle is capable of off-road operations, contains two 27 kilowatt generators,
and has an eight foot satellite dish antenna for KuBand operations. The microwave
link is capable of connecting with commercial telephone office's 14 miles from the
operations site. The MRV has been adapted for an airlift option of deployment.
2. Radio Frequencies: The following options are provided for planning and
operational considerations.
* Headquarters, USEPA have been requested to allocate and assign frequencies
to ERRB for response and administrative purposes. These frequencies will
constitute the basis for all communications capabilities for ERRB activities.
As of publication of this plan, frequencies are not allocated or assigned.
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* Temporary radio frequencies can be obtained from FEMA. Normally,
frequencies would be assigned to support FRP activities. Operational rules
and restrictions imposed by FEMA will have to be adhered too when using
their frequencies.
* Sharing of frequencies with State/local governments during response
operations within their area can be arranged. Operation rules and restrictions
of the governments must be adhered too when using their frequencies. An
extensive listing of the government entity and frequencies is available in the
RRC.
* Sharing of frequencies with USCG units is a viable option. Primary entry into
the system will be through the USCG Strike Team.
3. Frequency Changes: The RRC is able to computer program frequencies into all
radios in the ERRB. Each response will be allocated frequency(s) for a particular
response event. When there are operations difficulties with frequencies changes
can be accomplished.
4. Repeaters: Repeaters aid in getting more distance between radio stations.
Where available, they can be rented. Another option is to use repeaters mounted
in aircraft.
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ANNEX F
SENSITIVE ENVIRONMENTAL & ECONOMIC AREAS
PURPOSE: Response actions require extra care to protect the natural
environment in and around the spill location. Different eco-systems have varying
levels of resistance and resilience to spill contaminants. There are areas around
waterways which contain critical habitats and endangered species which may
require more specialized consideration and protection than other areas.
Deployment of protection devices such as booms and weirs along the river will
serve to protect the overall environment but quick and accurate identification of
sensitive areas is crucial to reducing the overall impact of the spill.
Contained in this annex is an outline of factors which can be used to identify
sensitive environmental areas as well as economic areas.
SCOPE: The purpose of this annex is to provide the Incident OSC with relevant
information to assist in the identification and determination of sensitive
environments. Outlined within this Annex is information which can be utilized to
distinguish sensitive areas found throughout the Region. It is not the intent of this
annex to provide a complete and total listing of every sensitive area; a thorough
listing of all these areas would be to large to be useful. Provided are a list of
factors which should be taken into account when assessing potentially sensitive
areas. Also included as an Appendix, is a catalogue of lists which provides
information on environmentally susceptible areas, such as National Parks,
Wilderness areas, and undeveloped sections of rivers. The goal of this annex is to
increase awareness of sensitive areas as a whole and to provide the Incident OSC
with sufficient information to facilitate the identification process.
There is no way to outline a regimented and systematic approach to protecting all
sensitive environments for every spill. Each spill is unique in the manner and
volume of the material spilled as well as in the location along the waterway. These
dynamic factors prevent the drafting of a concrete response plan. Rather, the
information contained in this Annex should be used to provide insights into the
types of environments effected by a spill and what areas warrant greater and or
immediate concern. It is an unfortunate fact that eco-systems will be impacted by
a spill, and that some of the eco-system may have to be sacrificed in the cleanup
effort. However, it is the goal of this Annex to provide information which will help
the Incident OSC to identify sensitive areas and take the appropriate measures to
minimize the impact of the spill.
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RESPONSIBILITIES: The following is a description of the roles and
responsibilities of Agency personnel during a spill response.
A. INCIDENT OSC: As prescribed in the NCP, the Incident OSC's role is to
facilitate cleanup activities and to insure proper measures are taken to
remediate the incident. The OSC's function is to work in cooperation with
the responsible party and state agencies to provide a quick and effective
cleanup. It is preferable for the responsible party and the state to take the
lead in a cleanup operation, however the USEPA may have to step to the
forefront of a response action to protect threatened habitat or species. The
OSC should work with other agencies to ensure that information about the
environment affected by the spill is gathered and distributed. Outlined in
this annex are various sources of information which the OSC may consult to
assist in determining and protecting sensitive environments endangered by
the spill.
B. STATE AGENCIES: Each state in Region IV has a department or office
charged with protecting the natural resources of that state. Many of these
state agencies catalog and monitor sensitive environments. These personnel
should have more detailed information about the environments effected by a
spill.
C. CLEANUP TEAMS: Lead by an OSC or a representative of the OSC, it is the
clean teams responsibility to minimize the overall impact the response action
inflicts on the natural environment. Efforts to cleanup the spill should be
carefully planned to prevent additional damage. Cleanup teams should be
directed to address the most sensitive areas first when ever possible.
D. ADVANCE TEAM LEADERS: Advance teams are the forward units in a
response action. It is their role to evaluate and identify sensitive areas prior
to spill contact. The advance teams should be deployed far enough ahead of
the spill to take protective measures to preserve sensitive environments.
Examples of protective measures include, but are not limited to, booms,
dams, or other diversion measures to lessen the impact of the spill.
E. NATURAL RESOURCES TRUSTEES:
1) Department of Interior (DPI) - US Fish and Wildlife Service (USFWS)
This Agency is charged with monitoring and protecting the natural
resources found in the United States. Fish and Wildlife maintains lists
of endangered species and will be called out to the scene to monitor
the environmental impact of the spill and response actions. The Fish
and Wildlife can provide additional information concerning natural
resources issues, endangered species, sensitive habitats, and wildlife
rescue.
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2) National Oceanic and Atmospheric Administration (NOAA)
F. PRIVATE ORGANIZATIONS
1) State Natural Heritage Programs: All states in this Region have State
Heritage Programs to locate and monitor bio-diversity in their state.
These programs have been setup in joint cooperation with The Nature
Conservancy and the states of the Region. Individual agreements are
being setup between the Agency and the states to provide incident
specific information concerning threatened and endangered species in
the event of a spill. No date has been established as to when these
agreements will be in place.
2) Conservation Groups: Many natural areas are monitored by local and
national conservation groups, such as local fishing clubs like Trout
Unlimited and member organization such as The Nature Conservancy.
Local groups can be contacted at the time of the spill to obtain
information on waterways they monitor and are potential sources of
information on the local natural resources. Many national groups
often maintain wilderness preserves. A listing of these holdings is
provided in Appendix 2.
{MORE TO BE ADDED LATER)
PROCEDURES:
INITIAL PROCEDURES: On arrival at a spill, the Incident OSC must make an initial
assessment to determine the material and volume of the spill. As a part of this
initial assessment, it is necessary for the Incident OSC to determine the
geographical and environmental factors of the area surrounding the spill in order to
plan the proper protective and remedial measures. Guidelines for determining
whether an environment is sensitive are presented in the next section. The steps
for the ascertaining the environmental impact of the spill are as follows:
Spill site: Investigate the spill location and the natural areas already impacted to
determine the extent of damage. Determine if any immediate actions at the scene
can lessen further damage. At the spill site, the Incident OSC should determine
the direction and rate of the flow. Immediate steps should be taken to stop the
additional release of material and to contain the spill.
Areas of immediate danger: Following the assessment of the spill site, the OSC or
representative should examine the areas immediately downstream or adjacent to
the spill, which although may not have been effected by the spill, are in immediate
danger of contact with the spill. (Immediate danger can be defined as impact
occurring in a matter of hoursJ If sensitive areas are located, then preemptive
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measures should be taken to minimize the spill's impact prior to contact. This
includes, but not limited to, booms, dams, or other diversion measures to lessen
the impact of the spill. Preservation of a sensitive area depends on actions taken
prior to spill contact.
Areas of potential danger: While steps are being taken to control the spread of the
spill, the Advance Teams shall conduct a reconnaissance to determine what other
sensitive areas might be impacted if the spill flows further downstream. If
sensitive areas are located, provisions shall be made to protect these areas in the
event of further release. Preparation should be made for the deployment of
additional cleanup teams, in the event of a breakthrough of previously contained
material.
SECONDARY PROCEDURES: Once a sensitive area has been identified and
protective measures have been taken, the Incident OSC shall monitor the integrity
and effectiveness of these measures. A minimum daily inspection will be carried
out to ensure that the protective measures are holding in place and no additional
measures are needed. The Incident OSC will also designate a qualified person,
such as wildlife biologist, to monitor the ecological health of the threatened area.
{IS THERE A VOLUME DEFINITION OF MINOR, MEDIUM, MAJOR, OR WORST
CASE SPILL?}
DESCRIPTION OF SENSITIVE AREAS
1. GENERIC CRITERIA: The following is a partial listing of the area types which
might be considered sensitive, either environmentally or economically.
ENVIRONMENTAL
A. Wetlands: Marshes, swamps, and other areas where water flow is usually
slow and has a high occurrence of vegetation. These areas support a large
amount of species diversity and can be used by these species for breeding.
B. Endangered species: Areas which contain endangered species, both flora
and fauna, exist throughout the Region. These species are often found in
well defined preserves, but they may also exist in small remote populations.
For example, in the State of Georgia, a species of river lily exists in only one
location, a sand bar in the middle of a particular river.
C. Critical habitat: These areas support communities of animals and plants
which although might not come into direct contact with the spill, rely on the
waterway for food, habitat, or breeding grounds. If a river becomes
contaminated, this may reduce the source of drinking water and food for
upland species.
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D. Natural Areas: These are areas which posses value as a whole eco-system.
They may not contain endangered species, but are representative of the eco-
system in its most natural state. Examples of these areas are outlined in the
Outstanding Rivers List or the List of Wild and Scenic Rivers, which are
presented in Appendix 2.
2. CHARACTERISTICS TO DETERMINE AND IDENTIFY SENSITIVITY: The
following factors are to be utilized in determining sensitivity of an area. These
factors are not the only criteria for determining sensitivity, but are presented here
to provide a general formula.
ENVIRONMENTAL FACTORS
A. Geography: Examine the position of the river or waterway. River and lake
characteristics differ whether they are positioned in the Piedmont or Coastal
Zone. Refer to a map of the state to determine in what zone the waterway
is located. The Piedmont Zone lies above the fall line and it's waterways are
distinguished by shallow, fast-flowing rivers which usually have many
changes in direction. The forest surrounding a Piedmont Zone river
predominately consist of hardwoods and the land slopes sharply to the river.
Below the fall line, in the Coastal Zone, the rivers straighten and widen with
a steady flow. The land around the river has a more gradual slope.
Many of the larger lakes in the Region have been developed by the
construction of dams along rivers. These areas are widely used by
communities for recreation and a spill can impact these activities.
Conditions vary whether a water way is a tributary stream or major river.
Tributaries not usually not as fast-flowing as major rivers and are often used
as breeding grounds for aquatic wildlife. Also, tributaries do not "flush out"
as fast as major rivers and spill material may collect in pools or eddies.
B. Season: Water flow and the dispersion of flora and fauna varies widely with
the season. Determine what species and habitats are more susceptible at
different times of the year. In the winter time, vegetation is dormant and
less vulnerable than in the summer growth seasons. The animal
communities found in and around a waterway also differ in members and
numbers throughout the year.
C. Habitat: The types of habitat that may support endangered species are not
uniformly distributed on rivers, even those rivers which are similar. Evaluate
the potential for sensitive habitats by the amount of development present on
the river, the impact of past spills or whether the location could be
considered pristine.
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D. Lists/Maps: Consult Ecologic Information Catalog, contained in Appendix F1
& F2 for a listing of potential environmental and ecologic areas found in the
Region. This listing outlines areas such as protected sections of rivers,
public and privately held conservation areas, and State and National Wildlife
areas. Also, included is a listing of endangered species by county for each
state in the Region along with a state map. Consult these resources for
information on areas immediately effected by a spill and areas which might
be impacted as the spill progresses, in the future, the Region hopes to
develop a Geographical Information System program which will incorporate
all relevant data onto a computer based system.
E. Local Resources: Determine what local sources of information are available
for the area of the spill. Consult State Heritage Programs or local
conservation groups for detailed information concerning impacts a spill might
have on the areas biologic systems.
F. On-Scene Conditions: Use own observation and the information gathered by
advance teams concerning the factors are present at the spill and the areas
likely to be impacted. Conduct reconnaissance of waterways to determine
what areas are likely to be sensitive and then verify or deny. All spills have
different components, as do ail eco-systems and natural habitats. Use all
information possible to determine the best method for determining the most
effective strategy for protecting sensitive environments.
ECONOMIC
Economic sensitive areas have been determined by the OH Pollution Act of 1990 as
public drinking water intakes. These facilities are located on the shores of streams
or rivers used as a municipal water source. These intake points can be located by
contacting the local agencies concerned with local water supply.
These agencies should be notified of the spill as soon as possible and advised to
prepare for the protection of the municipal water intakes. Additional protection
measures may have to be undertaken to prevent the contamination of the local
drinking water supply.
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APPENDICES
information concerning sensitive areas are attached to this annex in two
appendices outlined below.
{THIS INFORMATION IS STILL BEING PREPARED}
APPENDIX F-1 - Endangered Species Information
Appendix F-1 provides a listing of endangered species, presented for each state by
county, found throughout the Region. Provided is a map of each state, showing
the county boundaries and the watersheds. When a spill occurs along a particular
waterway or body of water, the spill site is located by the county in which it
occurs. Once the county is known, its location is determined on the map by using
a directory provided with the map. The responder then turns to the list for
endangered species in that county. Adjacent counties can also be located on the
map to identify species that might be threatened downstream from the spill.
Also provide in Appendix F-1 are contacts for additional sources of information.
Included are contacts with the U.S. Fish and Wildlife Service, the State's Natural
Resources Departments, the State's Natural Heritage Programs, and other relevant
agencies and services which might provide information on endangered species.
APPENDIX F-2 - Critical Habitat Catalog
Appendix F-2 provides information on the critical and endangered habitats found
throughout the Region. Information is provided on parks, preserves, refugees, and
protected areas. The information is presented in a category by category format
and maps are provided to aid in the location of the habitats.
ADDITIONAL INFORMATION SOURCES:
AGENCY RESOURCES
* Regional Response Center
Located in the Region IV Headquarters; Response Center contains
sources of information and resources developed in this Annex.
Included in this information is the identified sensitive environments for
Region IV.
* National Response Center
* Regional Response Team
* National Response Team
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ADDITIONAL RESOURCES
# U.S. Fish and Wildlife Service
This agency monitors and protects the endangered species found
throughout the United States
* State Natural Heritage Programs
These programs monitor bio-diversity in the individual states. They
have been described above and contact sheets are included in
Appendix 1.
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SUMMARY OF 40 CFR PART 112, APPENDIX D
The following has been compiled from Appendix D of 40 CFR 112, which is
concerned with the Oil Pollution Act. The information summarized below covers
sensitive environments and critical habitats. For detailed information on this topic
refer the Appendix.
RESPONSIBLE FEDERAL AGENCIES FOR
SPECIFIC ENVIRONMENTAL RESOURCES
AREAS
RESPONSIBLE
AGENCY
WETLANDS, as defined in 40 CFR 230.3
USEPA
CRITICAL HABITAT for endangered/threatened species
NOAA
USFWS
HABITAT used by endangered/threatened species
NOAA
USFWS
MARINE SANCTUARIES
NOAA
NATIONAL PARKS
DOI - NPS
FEDERAL WILDERNESS AREAS
USDA
COAST ZONE MANAGEMENT ACT designated areas
NOAA
NATIONAL ESTUARY PROGRAM
NOAA
NEAR COASTAL WATERS PROGRAMS areas
USEPA
CLEAN LAKES PROGRAM critical areas
USEPA
NATIONAL MONUMENTS
DOT
NATIONAL SEASHORES RECREATIONAL AREAS
DOI - NPS
NATIONAL LAKESHORE RECREATIONAL AREAS
DOI
NATIONAL PRESERVES
DOI
NATIONAL WILDLIFE REFUGES
NOAA
USFWS
COASTAL BARRIER RESOURCES SYSTEM {units,
undeveloped, partially developed)
USFWS
CONTINUED ON NEXT PAGE
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RESPONSIBLE FEDERAL AGENCIES FOR
SPECIFIC ENVIRONMENTAL RESOURCES
CONT
• AREAS
RESPONSIBLE
AGENCY
National River Reach designated as recreational
USEPA
Federal or State designated scenic or wild river
DOI
National Conservation areas
DOI - BLM
Hatcheries
USFWS
Waterfowl management areas
USFWS
(Taken from Attachment O-I, Appendix DJ
NOTE:
WHERE USEPA IS DESIGNATED AS THE RESPONSIBLE AGENCY, THE
INFORMATION WILL BE PROVIDED BY THE APPROPRIATE REGIONAL OFFICE.
PLEASE CONTACT STATE AND LOCAL AGENCIES FOR INFORMATION ON
RESOURCES THEY MANAGE.
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ANNEX G
WORKER HEALTH AND SAFETY
PURPOSE: When conducting a response, quick actions are needed to minimize
the impact of the spill and to prevent further migration of the spill. Also crucial is
the health and safety of workers, both contractors and volunteers, is crucial. A
plan must be developed from the onset of response actions outlining the proper
working conditions necessary to ensure the safety of cleanup personnel. No
response can be considered effective if personnel are injured and the need for a
swift cleanup is put ahead of health and safety concerns. The Incident OSC is
responsible for inspecting and correcting poor or dangerous work conditions. The
OSC needs to monitor ail health related issues and dedicate specific Health and
Safety oversight personnel when necessary. It is possible to prepare a generic
safety plan which can be used in the event of an emergency spill response action.
The plan must contain the appropriate attachments to cover the work required.
Safety guidelines concerning worker health and safety are outlined in 29 CFR
1910.120 and should be consulted in the development of a response plan.
SCOPE: This Annex provides the necessary information for the Incident OSC
to construct an emergency response oriented safety plan. The scope of a safety
plan should provide the basic safety guidelines and attachments which cover the
work anticipated onsite. Provided in the Appendix of this Annex are various
guidelines and SOPs which can be used to construct a non site specific safety plan
to be used in emergency situations. In the event of a release, the Incident OSC
can refer to the index of attachments provided in the Appendix and select the
relevant information. These files can then be used to form a safety plan covering
the known hazards occurring at the spill.
RESPONSIBILITIES:
A. INCIDENT OSC: It is the overall responsibility of the Incident OSC to determine
the appropriateness of the level of health and safety measures taken during the
course of a response action. When the State or the responsible party have taken
the lead in a response, the OSC should review the implemented safety procedures
and determine if they are adequate for the given situation. If the level of safety
does not meet the proper guidelines, an unaddressed health or safety concern
exists, or the OSC determines that a threat to the health and safety of onsite
worker exists, then the OSC may take measures to correct the situation. If the
deficiency is not repaired, the Incident OSC has the authority of take over the
response action.
If the response actions are being conducted by the Agency, then the OSC has the
final decision on health and safety protocols for the removal. It is the responsibility
of the OSC designate a site health and safety official, either the OSC or other
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qualified representative, to insure that no unsafe work practices are conducted. If
the clean up is large enough to warrant a cleanup team(s), then the team leader(s)
will be responsible for the safety of each crew,
B. DESIGNATED HEALTH AND SAFETY OFFICERS: The Incident OSC shall
assume the role of the site safety officer or designate a site health and safety
officer upon arrival at the response scene. The function of the site safety officer is
to coordinate all health and safety issues and to monitor site activities for safety
concerns. The site safety officer role is to ensure that all workers are properly
trained, to organize the training of volunteer workers, and to prevent untrained
personnel from entering the work or contaminated areas. Additionally, the site
safety officer performs morning safety meetings and monitors onsite activities,
performing medical and heat/stress monitoring as necessary.
C. CLEANUP TEAMS: Cleanup teams are responsible for physically removing the
spilled material from the effected areas. It is the responsibility of the team
leader(s) to take the appropriate steps to insure that all safety regulation are
followed and to ensure the health and well being of the crew. The leader should
make sure that the crews have all the necessary equipment and materials needed
to conduct cleanup operation in a safe, effective manner. Examples of these are
as follows; life jackets for water work, waders and gloves for shore work, and
where applicable, monitoring equipment to detect the buildup of dangerous fumes
or vapors. Also, the leaders need to ensure that the crew have the appropriate
amount of material support with such items as replenishing drinks, warm clothes
and transport. Health and safety issues relate to all aspects of the cleanup
operation, not just contact with the released material.
D. ADVANCED TEAMS: Advanced teams are responsible for reconnaissance of
the river downstream from the spill site. Although these personnel will not, most
likely, come into contact with the spill, travelling along the waterway posses
dangers to the personnel. Investigating the shore of the waterway or lake often
involves moving along rocky or slippery shorelines. Care must be taken that crew
members do not slip and fall into the water. They might be taken downstream, or,
in the case of a winter spill, be immersed and succumb to hypothermia. If
reconnaissance is conducted by vehicles, care should be taken that the proper
operation SOPs are followed. SOPs for boat and helicopter safety are to be found
in Appendix G-1.
E. MANAGEMENT SUPPORT: The Incident OSC or the site health and safety
officer can call on Agency management to obtain health and safety information
from the Regional Response Team
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F. OCCUPATIONAL HEALTH AND SAFETY ADMINISTRATION (OSHAJ: OSHA is
a division of the Department of Labor which regulates work and health safety
issues. OSHA's role and responsibilities are outlined in 29 CFR 1910.120 and
these regulations cover hazardous material worker safety. Site safety plans and
safety precautions are also mandated by these regulations. OSHA has the power
to inspect response site to determine if all necessary safety precautions are being
met. To insure that all health and safety issues are being addressed, select a
qualified individual to be the site health and safety officer, this being a person with
adequate experience and training, and consult an industrial hygienist or health and
safety professional on any questions or concerns.
{MORE TO BE ADDED)
PROCEDURES:
PRE-RESPONSE PROCEDURES: Before responding to a spill, responders needed to
identify the material in order to determine the associated health risks. If an exact
determination of the spilled material can not be obtained, the most likely suspected
material should be used to formulate a health and safety plan. The plan should be
developed to provide sufficient safety information to cover all expected work and
provide provisions for obtaining additional information as soon as possible. It is the
responsibility of the Incident OSC to put the safety plan into effect upon arrival at
the scene.
INITIAL ONSITE PROCEDURES: Upon arrival on site, the Incident OSC should
initiate the safety measures outline the plan, if safety measures have not already
been implemented by either the responsible party or State. If appropriate, the
Incident OSC shall designate a site health and safety officer. If safety measures
have been implemented, the Incident OSC should inspect these measures to
determine if the are appropriate and if they should be expanded. The OSC should
review all health and safety related issues to ensure they are no unaddressed
dangers and clearly any unresolved topics.
CLEANUP PROCEDURES: Once response work begins, the Incident OSC or the
health and safety officer should monitor and adjust health and safety procedures
and practices to ensure they match the work being conducted. If the scope of
work changes, the OSC should initiate the appropriate changes to the safety plan.
An overall safety protocol shall be implemented for extended response those
lasting more than just a few days. This protocol shall include such things as daily
meetings, air monitoring (if necessary), first aid and medical monitoring for heat
and cold stress. Proper protocols for these concerns are found in Appendix G
attachments (Refer to Index).
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APPENDIX G-1
GENERIC SITE SAFETY PLAN
SECTIONS
Section A
Site Description
Section H
Decontamination
Section B
Entry Objectives
Section /
Sanitation
Section C
Site Organization
Section J
Emergency
Procedures
Section D
Site Control
Section K
Communications
Section £
Hazard Evaluation
Section L
Safety Meetings
Section F
General Site Procedures
Section M
Safety Officers
Section G
Personnel Protective
Equipment
Section N
Authorizations
ATTACHMENTS
1) Generic Hazardous Substance
Information (Site specific)
13) Decon Layout
1a) Oils containing Benzene
14) Decon for Oil
1b) Oil not containing Benzene
15) Briefing Log
1c) Hydrogen Sulfide
16) PPE Ensemble Sheets
2) Site Maps
17) Helicopter Safety
3) Toxic Exposure Information
18) Small Boat Safety
4) Heat Stress (Short Form)
19) On-Site Medical Monitoring
5) Heat Stress (Long Form)
20) Safety Plan Evaluation
6) Cold Stress (Short Form)
21) Site Organizations
7) Cold Stress (Long Form)
22) Safe Practices for Bird Rehab
8) Sanitation Requirements
23) Products with Benzene
9) Confined Space Entry
Checklist
24) Training Evaluation
10) Safe Manual Lifting Procedures
25) Motor Vehicle Safety
11) Simplified Work Plan
26) Bites, Stings, and Plants
12) Monitoring Report Sheets
27) Container handling and Spill
Containment
Appendix G-1-1
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ANNEX G
WORKER HEALTH AND SAFETY g-i
PURPOSE G-1
SCOPE G-1
RESPONSIBILITIES G-1
PROCEDURES G-3
APPENDIX G-1
GENERIC SITE SAFETY PLAN .... Appendix G-1-1
Appendix G-
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ANNEX H
FUNDING AND CONTRACTING
PURPOSE; Under CERCLA and OPA, the party(ies) responsible for discharges or
releases are liable for cost of the response and cleanup. If the party is unable or
unwilling to act promptly to remove or mitigate the discharge, response actions
may be intitiated by the Incident OSC. In order to carry through on such a decision
there must be adequate funding along with support and documentation
mechanisms.
SCOPE: This Annex provides the Incident OSC and response staff with the
proper guidance to secure adequate response funding and adhere to applicable
contracting requirements. In addition, this Annex describes the funding
mechanisms available for response and outlines the procedures to follow to
properly document expenditure of those funds.
RESPONSIBILITIES and PROCEDURES:
A. Funding
1 • Hazardous Substances Releases: CERCLA funds are available to
respond to and cleanup hazardous substance releases. Region IV is given funding
on a quarterly basis. In the event that adequate funding is not available for the
response, USEPA HQ should be contacted immediately to obtain funding.
USEPA OSCs have been delegated emergency procurement authority of up to
$50,000. If that amount is not adequate to fund the response, the Waste
Management Division Director can approve a removal cost ceiling of up to
$2,000,000.
2. Oil Discharges: Funding for removal of oil discharges is available from the
Oil Spill Liability Trust Fund, managed by the USCG National Pollution Funds
Center. Procedures for accessing this fund are outlined in the Oil Spill Response
Checklist.
USEPA OSCs have been given ordering authority for BOA contracts of up to
$25,000.
1. Federal Project Number and Incident Ceiling: The Incident OSC is responsible
for ensuring that adequate funding is available to conduct the response and that
costs remain within established ceilings. Applicable duties for the Incident OSC:
a. Contact the appropriate USCG district to obtain a Federal Project Number
(FPN) and a cost ceiling.
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b. Monitor costs daily to ensure that cost ceiling is not exceeded.
c. Request ceiling increases from the USCG district when total project costs
reach eiahtv-five (?) percent of the incident ceiling.
d. Documentation Requirements: to be developed.
Z Reimbursable Account: A reimbursable account should be set up under the
following conditions:
a. When funds are needed for USEPA employees to travel to the incident.
b. When it becomes necessary for USEPA Contracting Officers to apply their
warrant authority to issue contracts for the response.
A reimbursable account may be set up with the USEPA Financial Management
Center, Cincinnati, OH using procedures outlined in the Oil Spill Response
Checklist. In the event that there is no existing blanket Interagency Agreement
(IAG) with the USCG, an incident-specific IAG may be used to set up a
reimbursable account.
3^ Natural Resource Damage Assessments: The responsibility for securing
funds for Natural Resource Damage Assessments shall rest with the relevant
trustee (s) for the incident.
B. Contracting
This section covers the mechanisms to secure both private and governmental
services to assist the Incident OSC in carrying out the response action. The
contracting function will reside in the Logistics section of the response
organization.
IL CONTRACTING OFFICERS
a- USCG Maintenance and Logistics Command: Atlantic (MLCLANT):
Located in Governors Island, NY, MLC is the primary contracting
authority for oil spills.
b. USEPA Contracting Officers: USEPA COs have the authority to
obligate USEPA funds. In order for an USEPA CO to commit oil
response resources on behalf of the federal government, a
reimbursable account would first need to be set up (see Funding).
USEPA COs may be requested by the Incident OSC through the
Regional Incident Coordination Team (RICT).
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CLEANUP CONTRACTORS
a. Basic Ordering Agreement (BOA) Contractors: BOA contractors may
be activated by contacting MLC. BOA contractors have pre-
negotiated rates for labor, equipment, and materials. A current list of
BOA contractors is maintained in the Blue Book.
b. USEPA Emergency Response Cleanup Services (ERCS? Contractors:
In a worst case discharge USUSEPA ERCS contractors may be called
on to respond. Because their contracts and ceilings are tied to
available CERCLA funding, the procedures outlined below for securing
the services of a non-BOA contractor should be followed.
c. Non-BOA Contractors: Securing the services of a non-BOA contractor
will require negotiation of rates by a CO. These contractors may
require some assistance in understanding documentation and invoicing
procedures. The USCG Maintenance and Logistics Command
publication will help the contractor understand this process.
d. TAT Contractor: Though not a cleanup contractor, the USEPA
Technical Assistance Team is available to provide assistance with
documentation, sampling and analytical requirements, and Mobile
Command Post Operations. TAT assistance is provided through the
issuance of a Technical Direction Document (TDD).
e. Oil Spill Response Organization (OSRO): The National Strike Force
Coordination Center, Elizabeth City, NC rates contractors on their
capabilities to handle various sized incidents based on where the spill
occurs. A contractor rated "E" is the most qualified, and an "A" the
least qualified.
GOVERNMENT AGENCY SERVICES
a. Federal: Refer to the Base Plan for the specific services each agency
can provide. Federal government agency services may be secured
through the use of a Pollution Removal Funding Authorization. When
time permits or where more detail is necessary, an IAG may be
negotiated with the relevant agency. The Coast Guard Strike Teams
do not require such documents for oil spill responses.
b. State: A state agency may be contracted through a Letter Contract.
The ceiling on this type of contract is $10,000.
c. Local: See b.
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SUBCONTRACTED PROCUREMENTS: Office space, equipment, materials,
labor, and transportation and disposal will, in most cases, be provided
through the various contract mechanisms and billed to the government as
part of the incident specific costs.
GOVERNMENT PROCUREMENTS: In the event that contractors cannot
provide certain goods and services, they will be procured by the
government, with Contracting Officers and procurement staff overseeing the
purchases. The Agency maintains a Mastercard/Visa which is available for
rapid, streamlined purchases. The per purchase limit for the Mastercard/Visa
is $2500. Purchases by USEPA will require a reimbursable account to make
the funds available.
PROCUREMENT CONSRRAINTS: The following information is provided as
general guidance on federal procurement regulations. A CO should be
contacted for specific details and to ensure that these rules are adhered to
throughout the incident.
The Federal Acquisition Regulations (FAR) §6.302-2 allow government
purchases without full and open competition in situations of "unusual and
compelling urgency". Federal response to a (major/ worst case?) discharge
meets the FAR criteria for "unusual and compelling urgency". Some
justification or certification must be provided after the fact at the following
levels of approval:
Under $100,000 Contracting Officer
$100,000 to $1,000,000 Competition Advocate
Over $1,000,000 Director, Office of Acquisition Management (OAM)
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AIVIVCA I
PUBLIC INFORMATION
PURPOSE: When an incident occurs, it is imperative to give the public prompt,
accurate information on the nature of the incident and the actions underway to
mitigate the damage. Those in charge of the response and associated public relations
personnel should ensure that all appropriate public and private interests are kept
informed and that their concerns are considered throughout the response. Sections
300.155, 300.415, 300.430 and 300.435 of the NCP require the establishment of
a means for coordinating, informing and updating the public during the response and
removal activities. A prompt and full information flow is essential to getting
cooperation from people and keeping them informed.
SCOPE: This Annex outlines the responsibilities responders, primarily the OSC, have
to the public during a response and discusses the resources available to fulfill those
responsibilities. It also provides a number of guidelines for handling media interaction,
public relations and political interest. Often the success or failure of a response effort
is not based upon what actually took place, but upon the information the media and
the community received. The following guidelines will assist in the development of
a successful public information system during a response.
GOALS OF A PUBLIC INFORMATION SYSTEM
1.
Reach the affected public as soon as possible regardless of the time of
day or night. Also provide updates on a routine basis or as incident
conditions change.
2.
Inform the public of the situation and all associated threats.
3.
Tell the public what actions to take.
4.
Give follow up information as to when the next update will be and who
they can contact for additional information.
5.
Clear all information through the OSC or Incident Commander prior to
release to the public.
RESPONSIBILITIES:
A. INCIDENT OSC: According to the NCP, the OSC and designated public relations
personnel are responsible for keeping both public and private interests informed of the
nature of the incident and the actions being taken to mitigate the threat. The size of
the OSC's public information staff depends upon the response situation. It is up to
the Incident OSC to designate the media and community spokespeopleforthe incident
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and allow them to coordinate public relations activities. When necessary, the Incident
OSC shall be available to meet with the media and local community members to
answer questions and present technical information.
B. USEFA COMMUNITY RELATIONS COORDINATOR (CRC): Primary resource for
coordinating the preparation of fact sheets, public meetings, community interviews
and any other activities to inform the community, residents and private interests,
impacted by the incident.
C. USEPA OFFICE OF CONGRESSIONAL AFFAIRS (OCA}: As a liaison for the
responders in the field, USEPA's OCA keeps dignitaries, State and Federal elected
officials and local representatives fully informed of all response events. The OCA is
also the official escort for prestigious site visitors.
D. USEPA OFFICE OF PUBLIC AFFAIRS (OPAff): Provides support in media relations
tasks, such as developing press releases, processing information requests from the
media, or acting as an Agency spokesperson. Assistance may be requested directly
from the Incident OSC or from the CRC.
E. PUBLIC INFORMATION ASSIST TEAM (PIAT): If requested, the PAIT will provide
personnel and expertise to the OSC needing additional assistance with the media. The
PIAT, a highly specialized, self-contained, public affairs resource, is available through
the National Response Center (NRC) or the USCG National Strike Force Coordination
Center (NSFCC).
F. JOINT INFORMATION CENTER (JIC): For major spills where media activity will
last more than 2-3 days or a large number of agencies and organizations are involved,
a JIC should be established to coordinate the Public Information activities of all
participating agencies and parties. This allows journalists and spokespeople to
coordinate media relations from a central location and ensures that accurate
information is released rather than rumors and speculations. If a JIC is established,
the spokesperson designated by the Incident OSC shall speak for all the agencies
present at the response. Each agency can speak for itself about their specific
activities, however not the activities of other agencies. Specific responsibilities and
additional information for the JIC are presented in Appendix 1-3.
PROCEDURES:
A. INITIAL PROCEDURES: The Incident OSC has primary responsibility for public
relations during a response. For effective and accurate information distribution, the
Incident OSC shall appoint spokespeople by using the following guidelines:
Minor spill: may only need one spokesperson who can coordinate information from
the Regional Office. The Incident OSC is the only on-site spokesperson.
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Medium or Major spill: both a media spokesperson (MS) and a CRC may be needed
on-site. May establish a support and briefing center near the incident. In addition, a
separate protocol officer (PO) may be needed to handle VIP visitors.
Worst case spili: a MS, a CRC and a PO shall be selected to conduct activities at the
incident. A JIC shall be established as the primary public affairs center.
B. MEDIA RELATIONS: conducted by the Media Spokesperson (MS)
1. Prepare press releases and media statements from information gathered
from the Incident OSC, POLREPS, fact sheets, etc. Update at least daily
or as status of response changes.
2. Brief the Incident OSC each morning on media coverage of the incident
and specific public affairs goals for the day. The Incident OSC should
update the press release at this time. If media interest is extremely high,
the OSC should be briefed more often than once a day.
3. Arrange for and coordinate press conferences as required by the
response events. A media availability session with the Incident OSC
should be conducted once a day during the critical days of the response
effort or when media interest is great. For additional information on how
to conduct a press briefing, refer to Appendix I-2.
C. COMMUNITY RELATIONS: conducted by the CRC
1. The CRC shall prepare fact sheets and distribute them to the impacted
community. Fact sheets may be updated as response events change or
as otherwise necessary. An example of the standard fact sheet format is
presented in Appendix 1-1 along with a generic fact sheet on oil spills.
2. If the threat to the community is significant or the interest is large, the
CRC may go door-to-door to meet with individuals and discuss any
concerns they may have. This is also an excellent opportunity for the
CRC to collect from the community, information about the release, the
responsible party(ies), etc.
All designated spokespeople report directly to the Incident OSC who should be continuously updated on
all media and community activities. In addition the incident OSC shall review all press releases, fact sheets,
and any other items before being released to the media or community. All media and community inquiries
should be directed to the appropriate spokesperson.
The primary purpose of the availability session is to put forth the Incident OSC's assessment of the
progress of the response, its secondary purpose is to answer media questions.
3. Arrange for and coordinate a public meeting or public availability session
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to inform citizens of ongoing activities and to receive citizen feedback on
the proposed course of action. The meeting is not a substitute for other
communication methods, but instead should provide a technical
presentation and the opportunity for a question-and-answer session.
Refer to Appendix 1-2 for guidelines for conducting public meetings.
D. INTERNAL INFORMATION: internal information is the process of informing the
response personnel of the status of all the response activities. At a minimum, all
personnel assigned to response duties should be provided with access to the daily
press releases and fact sheets. This will help ensure a consistent and accurate flow
of information. For additional information on communication during a response refer
to Annexes B and E.
E. VIP RELATIONS: conducted by the Protocol Officer (PO)
1. The PO can be selected from the OCA or another similar organization.
2. The PO shall be the liaison between the Incident OSC and all interested
VIPs (i.e., Congressional Representatives, local officials, politicians, etc.).
It will be up to the PO to gather information from the MS and CRC and
distribute it to the appropriate VIPs. The PO shall also coordinate air and
ground transportation for the VIPs when travelling to and around the site.
3. The PO shall also escort VIPs around the incident site. All tours must be
coordinated through the Incident OSC, in advance, to determine which
areas can be visited and which to avoid. The Health and Safety
Coordinator must also determine where people can go based upon their
40-hour safety training status.
4. When VIPs visit or tour the site, the Incident OSC shall make an effort to
meet and talk with them to answer questions and clarify information.
F. ACADEMIC INTERESTS and PRODUCT SALES REPRESENTATIVES: All individuals
and parties representing companies, schools and universities should be directed to the
designated Scientific Support Coordinator. Refer to Annex J.
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METHODS FOR INFORMING THE PUBLIC
The following discussion examines the various means of public involvement and information dissemination. It also shows the relativ
strengths and weaknesses of each strategy.
METHOD
STRENGTH
WEAKNESS
FACT SHEETS
go to Appendix f-1
Can include details and graphics regarding technical
activities; can Include points of contact and phone
numbers if people need more Information.
Often time consuming to distribute to each community
member; creates, possibly, more questions than
answers.
PRESS RELEASES
go to Appendix I-1
Can include details and graphics regarding technical
activities; can Include points of contact and phone
numbers if media members need more information; can
be faxed to media outlets.
Must make sure to distribute evenly to avoid giving one
media representative an advantage over another; should
be continuously updated on a regular basis until incident
is concluded or no more media interest.
DOOR-TO-DOOR
High credibility; provides details; can target to a specific
geographic area; reaches everyone; builds excellent public
relations; adds a personal touch and provides an
opportunity to address Individual concerns.
Takes time; occupies personnel who may be needed In
other aspects; cannot cover wide areas due to high
personnel requirements; expensive in both money and
time.
PUBLIC MEETINGS/
PRESS BRIEFINGS/
AVAILABILITY SESSIONS
go to Appendix 1-2
Best methods for providing detailed information In a brief
amount of time.
Must notify people about meeting; public and media
must be moderated to keep meeting from getting out of
control; cannot be easily called whenever information
needs to be updated; too many meetings will result in
loss of Interest.
TELEPHONE HOTLINE
(1-800-NUMBER)
Manned 8-10 hours a day; gives public instant access to
someone to answer questions; public feels less in-the-
dark.
Can be overwhelmed with calls; often have to limit who
has access to the phone number which reduces public's
access to information; need one person dedicated to
phone at all times.
RECORDED MESSAGES
Reduces the amount of time the MS, CRC, and PO must
spend on Individual phone calls; people can receive
updates at their convenience; often Is the most updated
source of information.
Must ensure that people receive phone number; must
keep updated; cannot use iargon or technical words that
are not widely understood by the public; does not allow
addressing of Individual questions or concerns.
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METHOD
STRENGTH
WEAKNESS
AM/FM RADIOS
Instant communication; provides detailed information and
frequent updates; nearly universal access; portable and
auto radios operate during power outages.
Users must be tuned In to receive Information; stations
give inconsistent priorities to news information; broad
reach of the transmission means areas and people not
affected by release receive the message.
TELEVISION
Gives event credibility; available In most households;
gives up-to-date, detailed Information; can show video
footage, graphics, diagrams, etc.; can cut into regular
broadcast to give emergency information.
Narrow window of opportunity since people work and
sleep; broad reach goes out to people not Impacted;
affected by power outages; cable channels are only
received by subscribers.
NEWSPAPER
Good for non-time critical Information; Inexpensive and
widely distributed; detailed coverage; good for meeting
announcements.
May only be published once a day or week; will not
Include up-to-the-minute information; may not reach a
large portion of the affected community.
TOUR OF SITE
Provides direct information to a limited number of people.
Not useful for large numbers of people; some degree of
physical risk.
POLREPS/SITREPS
go to Annex B
Contain site details in a specific format; good for internal
communications; can be edited for fact sheets and press
releases.
May contain confidential Information not releasable the
public.
DIRECT MAILINGS
Useful to inform people In a specific geographic area of
upcoming events or information that directly affects
them.
May be time consuming and logistlcally difficult; often
costly, especially If sending return receipt.
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HrrcivLiiA i- i.
FACT SHEETS and PRESS RELEASES
A. FACT SHEETS: The following Sample Fact Sheet should be used as a
template for the Incident Fact Sheets. The fact sheet is designed to provide the
impacted community with important incident details. Fact sheet should be written in
non-technical terms and updated as often as possible for distribution to the individual
members of the community.
Sample Fact Sheet
U.S. ENVIRONMENTAL PROTECTION AGENCY
FACT SHEET
"Name of Incident"
"Date"
CONTACT
PHONE: FAX:
SITUATION: summarize events to-date, explain how the responders got involved and
explain their rotes
WHAT HAPPENED (or is Happening now):
describe the spill, any response efforts, future plans, etc.
WHEN: give timeframes, progress expected, etc.
WHERE: exact locations, where was oil, where is it now, where is it going?
WHO: who is responding, what are there plans, etc.
HOW: how much does it cost, how long will it go on, etc.
WHY: explain why the release occurred, why certain methods are being used,
use this block to clarify any information from above that may confuse or mislead the
readers
Graphics/Pictures:
Additional Information:
Appendix 1-1-1
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B. PRESSRELEASE: The following Sample Press Release should be used as a
template. Press releases are designed to provide the media with important incident
details. They should be updated as often as possible and distributed to the media
points-of-contact via fax or over the wire.
Press releases are written in an inverted pyramid sequence. The most important
information is in the first paragraph. Remaining facts are then included in the release
in descending order of importance. Basic information for a press release must include:
who; what; when; where; how; and why.
Sample Press Release
US ENVIRONMENTAL PROTECTION AGENCY
Region IV
Office of Public Affairs
Name of Site
Location
Date
Current Site Activities
Brief Site History
Future Activities
Any other pertinent information
Appendix 1-1-2
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iiT JT JCaI^A#JLA. MTJk.
MEETINGS and BRIEFINGS
Guidelines: Pollution incidents that generate significant media and community interest
normally require press briefings and public meetings. Given the emergency situation and the
dangerous nature of the incident, people want immediate answers and the assurance that life will
quickly return to normal. It is not uncommon for such briefings and meetings to become
shouting matches filled with citizens, politicians, private groups, environmental organizations,
etc. each trying to express their concerns.
The following guidelines have been included to assist both the Incident OS C and the associated
public information officials in preparing for such events. Through careful preplanning much of
the tension can be removed from the actual meetings.
Quickly identify buildings that are large enough and available to handle the meetings
during their scheduled times. Try to find a location near the incident site. Possible
meeting sites include: fire stations, city halls, schools, police stations, or other state and
local government buildings.
If meetings and/or briefings are to be on a routine basis, be sure to publish the times and
locations well in advance.
Provide a press release, statement or press packet to the media prior to holding a press
briefing.
The CRC or MS should have a clear idea of the specific points to be discussed and
anticipate questions that may be asked. Rehearse questions with everyone making a
presentation at the meeting, especially the Incident OSC.
Keep meeting structured but flexible. This flexibility is required to address community
concerns which at times may be different from the scheduled agenda. If a meeting is
overly structured many community concerns will not be heard or addressed.
Be sure to invite top officials and make sure that they are up- to-speed on all special
interest topics.
Facilitate presentations and clarify information by using charts, diagrams and any other
available visual aides. This may require creativity due to the emergency situation and
often remote location of the incident.
If the meeting does get out-of-hand, end it whether all presentations have been given or
not. Do not become the victims for other peoples' pent up anger and frustration.
Appendix 1-2-1
0171
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ArnUTLUiV x-j.
JOINT INFORMATION CENTER
As stated earlier, the JIC is established when the response is expected to last several days or
there is overwhelming community and media interest.
RESPONSIBILITIES OF THE JIC INCLUDE:
1. Providing phone lines, manned by knowledgeable individuals, to answer incoming calls;
2. Ensuring state and Federal government information representatives are available;
3. Issuing press releases to the media and providing copies to response officials;
4. Scheduling and coordinating news conferences and media briefings;
5. Providing the party responsible for the spill (RP) an opportunity to coordinate their media
efforts with those of the OSC.
The JIC serves two purposes: to provide "one stop shopping" for journalists, and, to coordinate
media relations by locating all spokespeople together. Hie size of the JIC will depend on the
number of agencies involved and the level of media interest. A small JIC can be managed out
of a one or two rooms. However, larger JICs may require an entire building.
For larger JICs, a Director is needed to keep things running smoothly. Because the USEPA will
be the lead federal agency for a spill requiring a JIC, the Incident OSC shall select an USEPA
spokesperson to serve as the JIC Director. Specific sites for the JIC should be selected as soon
as possible after responding to the release. Find a location near the incident but separate from
the Incident Command Center. This allows for greater control over information flow without
disturbing the response operations. A large JIC usually contains three sections: a large
workroom with tables or desks for each represented agency; a separate room for journalists to
write and file stories; and a room for press briefings. If such rooms are provided, they must
contain enough phone lines to accommodate each agency's phone and fax machine.
1- Workroom: will be very busy and may be manned 24-hours a day. Figure on a
space large enough to provide a two-person work area for each organization involved.
The JIC will also need a room for the Director. Phone lines and fax machines are
essential.
2. Reporter's Room: can be veiy simple to allow reporters to work in private. Be sure
to provide phone lines to keep reporters from using the phone in the workroom.
3. Briefing Room: needs to be large enough to hold 20-30 reporters and several TV
cameras. It should have a podium or tables for a panel to face the audience during
question and answer sessions. Good to have two exits; one behind the podium to allow
representatives to exit without wading through reporters.
Under most spill scenarios, a JIC of this magnitude will not be necessary, however careful
preplanning can minimize the confusion created by a major or worst case discharge. The
National Strike Force's Public Information Assistance Team (FIAT) names and phone numbers
are located in the USEPA Emergency Response and Removal Branch's Blue Book.
Appendix 1-3-1
0172
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ANNEX J
SCIENTIFIC SUPPORT
PURPOSE: Responding to an oil spill or hazardous substance release requires
special expertise to identify and mitigate the immediate problem and prevent future
damage. Given all the demands during a response, Incident OSC faces having to
be the technical expert on all scientific issue or try to oversee a multitude of
experts that show up at the spill site. To assist with such tasks, a Scientific
Support Coordinator (SSC) and team (SST) are selected to advise the Incident OSC
on scientific and technical matters.
SCOPE: The SST can provide a variety of services during a response. This
Annex presents the most important, but often overlooked, roles required to
effectively assist the Incident OSC in managing scientific and technical demands.
The resources available for support are discussed along with specific
responsibilities.
RESPONSIBILITIES: The SST is managed by the designated SSM which acts
as a liaison between the Incident OSC and the scientific community. The
responsibilities of both the SSM and SST include:
1. act as the principal liaison for scientific information and will facilitate
communications to and from the scientific community on response issues.
2. Make recommendations to Incident OSC and Logistics Coordinator on
response strategies, technologies and priorities;
3. Prepare trajectory models and impact predictions;
4. Work closely with Natural Resource Trustees and resource managers;
5. Prepare and implement sampling and monitoring plans to determine the
extent of contamination and the effectiveness of cleanup actions;
6. Provide information regarding toxicology, health effects, etc. associated with
the oil or hazardous substances released;
7. Provide guidance and information on water treatment;
8. Coordinate response activities with wildlife rescue and rehabilitation
activities; and,
9. Act as the point-of-contact for research opportunists and product sales
representatives.
J-1
0173
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PROCEDURES: TO BE DEVELOPED
PRIMARY AGENCY RESOURCES:
1. USEPA Environmental Response Team (ERT): ERT has expertise in treatment
technologies, biology, chemistry, hydrology, geology and engineering. ERT's
primary functions for a response include:
a. 24-hour emergency response capabilities and assistance;
b. consultation in water and air quality criteria, health and safety
protocols, ecological risk assessment, interpretation and evaluation of
analytical data, and engineering and scientific studies;
c. development and implementation of site-specific safety programs;
d. provide specialized equipment for monitoring, analytical support,
waste treatment and containment and control;
e. technical expertise for enforcement issues;
f. training;
g. technical experts for presentations at public meetings;
h. design specialized computer software to assist in hazardous material
cleanup and remediation;
i. operate and evaluate instrumentation and field response systems;
j. sample and analyze air, water, and soil and perform biological and
ecological assessments; and,
I. conduct on-site health and safety assistance.
2. NOAA Scientific Support Coordinators (SSC): SSCs are available, at the
request of the OSC, to assist with actual or potential responses to
discharges of oil or relapses of hazardous substances, pollutants or
contaminants. Generally, SSCs are provided by the NOAA in coastal and
marine areas. Typically, ERT acts as the USEPA SSC during inland events,
however NOAA SSCs can provide expertise in chemistry, plume trajectory
modeling, natural resources at risk and data management.
3. Agency for Toxic Substances and Disease Registry (ATSDR): As part of the
Public Health Service (USPHS), ATSDR provides emergency response
assistance, gives health consultations in public health emergencies, provides
technical assistance and estimates health risks to humans from exposure to
hazardous substances. Specific roles during an emergency include:
IL Health Assessments: evaluate data and information on the release of
hazardous substances into the environment in order to: assess
current or future impact on public health, develop health advisories or
other health recommendations, and identify studies or actions needed
to evaluate and mitigate or prevent human health effects.
bi Toxicoloaical Profiles: summarize and interpret available data on the
J-2
017 4
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health effects of hazardous substances and to initiate toxicological
and health effects research, where needed.
a Emergency Response: provide health-related support in public health
emergencies, including public health advisories, involving exposure to
hazardous substances.
4. USCG Strike Teams: USCG Strike Teams can provide technical support in
communications, oil and hazardous substances removals, shipboard damage
control, and are equipped with specialized containment and removal equipment.
The Strike Teams also have rapid transportation capabilities.
5. Technical Assistance Team (TAT): As a contractor to the USEPA, the TAT
provides personnel, materials and equipment to augment response activities. In a
spill situation, TAT personnel are under the direction of and provide support to the
Incident OSC, however they can serve as member on the SST. Specific science
and technical related activities include, but are not limited to:
a. collecting samples;
b. providing analysis of samples at a USEPA contract lab or a non-
contract lab, if necessary;
c. providing data to identify the existence and extent of a release, the
source and nature of the release and the extent of danger to the
public;
d. identifying personal safety requirements;
e. monitoring cleanup personnel;
f. evaluating disposal options;
g. assisting in the assessment of the feasibility and effectiveness of
containment, on-site treatment and removal options; and,
h. performing surveillance activities.
6. Emergency Response Contracting Service (ERCS): provide equipment,
personnel, etc. serve in a support role rather than a advisory role although they
can provide input to assist the IOSC in making a decisions.
7. USEPA Emergency Services Division (ESD): sampling assistance
J-3
cm
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SECONDARY AGENCY RESOURCES:
1. USEPA Office of Research and Development (ORD):
2. USCG National Strike Force Coordination Center (NSFCC): The USCG NSFCC,
located in Elizabeth City, North Carolina, is the coordination center for the
three USCG Strikes Teams {Atlantic, Gulf and Pacific). An OSC may call on
the NSFCC for the following support during a spill response:
a. Technical assistance, equipment and other resources;
b. Coordination assistance for use of private and public resources; and,
c. Assistance in locating spill response resources, both nationally and
internationally.
3. Radiological Assistance Teams (RATs): RATs have been established by
USEPA's Office of Radiation Programs (ORP) to provide response and support for
incidents or sites containing radiological hazards. Expertise is available in radiation
monitoring, radionuclide analysis, radiation health physics, and risk assessment.
RATs can provide on-site support including mobile monitoring laboratories.
4. USCG Public Information Team (PIAT): The Coast Guard PIAT is available to
assist OSCs to meet public information and participation demands.
5. US Geological Survey (USGS):Although the USGS typically provides assistance
with long-term remedial Superfund sites, they can provide information on surface-
and groundwater resources and hydrogeological data around the area of a spill.
Other, more specific services provided by the USGS include: well drilling, borehole
geophysics, surface geophysics, data review and search, monitoring, and data on
average flow for streams and rivers.
J-4
0176
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APPENDIX J-1.
OTHER RESOURCES
CURRENTLY BEING DEVELOPED.
Appendix J-1 -1
-------
APPENDIX J-2.
COMPUTER RESOURCES
This appendix is intended to serve as a reference for chemical and response
information available through several commonly used computer on-line systems.
Each system is briefly discussed in order to give readers a very general idea of the
type of information available. Instructions for logging into each system are
contained in the USEPA Region IV ERRB's Field Operations Blue Book.
ATTIC - Alternative Treatment Technology Information Center: a comprehensive
information network providing up-to-date information on innovative treatment
technologies including biological and chemical treatment, solidification and
stabilization, physical and thermal treatment. Available through the ATTIC System
Operator or an easy to use on-line computer system.
CAMEO - Computer-Aided Management of Emergency Operations: designed to
help emergency responders plan for, and safely handle, chemical incidents.
Contains nomenclature and response information on more than 4,000 commonly
transported hazardous chemicals. Also contains an air dispersion model to assist in
evaluating release scenarios and evaluation options. Can also be used for:
response information, mapping capability, information on fire and explosion
hazards, first aid, health effects, fire fighting, spill cleanup procedures and air
dispersion monitoring for 700 airborne chemicals.
ERTBB - Environmental Response Team Bulletin Board: method of communication
between OSCs and ERT. The bulletin board contains several areas of specific
information such under various conference titles. These conferences contain
information OSCs can retrieve such as copies of ERT Standard Operating
Procedures and various other software packages. Accessed via modem.
OHMTADS - Oil and Hazardous Material Technology Assistance Data Systems:
includes chemical identification information, such as chemical name,
manufacturer's name for the chemical. Chemical Abstract Service (CAS) number
and physical properties. Data pertinent to response efforts includes: toxicity
information for humans, flora and fauna; flash point reactions with other
substances; protective equipment necessary for cleanup operations; transportation
information; disposal information; and, methods of evacuation.
VISITT - Vendor Information System for Innovative Treatment Technologies:
provides environmental professionals with rapid access to up-to-date information
on innovative technologies and the companies which offer them. VISITT entries
display the vendor name, address, phone number, technology descriptions,
highlights and limitations, and the contaminants and waste/media treated. Many
vendors also provide a summary of performance data, project names and contacts,
unit price information, and literature references. VISITT" is available on disk.
Appendix J-2-1
0173
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ANNEX K
DISPOSAL
PURPOSE: In the early phase of a response all efforts are usually focused on
stopping the release and preventing its further spread. As these activities are
being completed, efforts suddenly shift towards the removal of the spilled material
from the environment. Often times this raises a new set of problems. Before a
major removal of the material can begin the following questions have to be
answered. How to get the material out? Where to store it? Where to send it?
How to transport it? State and local officials should be contacted during the early
phases of the response to determine the location and availability of additional
disposal facilities or disposal options. It is the responsibility of the Incident OSC
for determining the best disposal options for the various waste streams. Provided
in this Annex is a listing of the options available at the time of plan development
and the Incident OSC should verify the compliance status of a facility prior to
shipping waste for disposal. Additional disposal facilities and options may have
become available since the drafting of the ACP and these should be investigated.
SCOPE: The scope of the information provided in Annex K is limited to the
emergency phases of a response. It is intended to provide the Incident OSC with
sufficient resource material to select options for the transport, storage, and
disposal of spilled material as it is being removed from the effected waterway. It
does not cover methods for treatment and disposal of low-level contaminated
wastes, nor does it cover long-term mitigative measures. In-situ methods, such as
inplace burning or bio-remediation, are also not covered in this Annex. For specific
response and containment measures leading up to disposal, see Annex D,
Response Strategies.
RESPONSIBILITIES: The following is a listing of the responsibilities of the
Incident OSC and other possible participants in a response action. For low volume
spill, the Incident OSC's duties may overlap into the other areas listed below.
A. INCIDENT OSC: It is the responsibility of the Incident OSC for determining the
best disposal options for the various waste streams. In this decision, the Incident
OSC shall consider the following factors; environmental tradeoffs, applicability and
effectiveness of the technology, costs, the results of consultation with State RRT
representatives, and any other relevant information concerning the disposal of the
waste material. The Incident OSC must approval all disposal actions and insure
that the method chosen provides the best possible disposal solution of the waste
stream. In addition, the Incident OSC will insure that the facility chosen is in
current compliance nor has other issues which would interfere with proper disposal
of the waste stream. The Incident OSC is responsible for signing all hazardous
waste manifests and insuring that all material is transported in a safe and
appropriate manner.
K-1
01:
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The Incident OSC shall contact members of the RRT and other agencies, such as
the NRT, RICT, and Scientific Support personnel, to determine if there are new and
more appropriate methods for treating the spilled material.
B. CLEANUP TEAM OSC: This responsibility can be covered by the Incident OSC
on smaller spills or a qualified person can be appointed by the Incident OSC. It is
the responsibility of this OSC, as leader of the cleanup teams, to monitor cleanup
efforts on the scene and to ensure that the chosen recovery and disposal methods
are being properly implemented. This individual shall monitor the pumping or
skimming of oil off the water's surface to ensure that the water to oil ratio is kept
at a minimum. Excess water in the oil will complicate disposal and can increase
disposal cost and the decrease chances for the oil being recovered for later use.
C. ADVANCE TEAM LEADER: This responsibility can be covered by the Incident
OSC on smaller spills or a qualified person can be appointed by the Incident OSC.
It is the responsibility of the Advance Team leader to estimate the logistical
demands of implementing the chosen disposal methods and notifying the Incident
OSC of any obstructions or problems with this implementation. The Advance
Team leader should identify potential staging areas for recovery equipment.
PROCEDURES: The following sections outlines the process which the Incident
OSC should undertake to evaluate the proper disposal method for a spill.
WASTE STREAM IDENTIFICATION
The first disposal step which shall be undertaken by the Incident OSC is to identify
the types of waste streams created by the particular release. The Incident OSC
shall review the particular circumstances of the response and identify the waste
streams needing to be addressed. The following waste streams may expect to be
generated during an oil spill removal:
WASTE STREAM
W"m fk » M
Free Product
Contaminated Soil
Contaminated Debris
Contaminated Water
Contaminated
Clothing/PPE
K-2
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DISPOSAL OPTIONS
TEMPORARY STORAGE:
One of the OSC's major goals will be the removal of the spill material and
associated waste streams from the environment. On many responses, it may be
necessary to arrange for the temporary storage of recovered material while waiting
for waste profiling and the selection of a disposal facility. On a large spill, the
amount of waste generated may exceed the capacity of available treatment and
disposal facilities and waste streams may require temporary storage prior to
disposal. The options available for temporary storage vary according to the size of
the incident and the volume of waste recovered.
MINOR SPILLS (< 1,000 gallons)
1. Free product and contaminated water may be contained in tankers,
portable pools or portable tanks.
2. Contaminated soil, debris, and clothing may be contained in drums or roll-
off containers.
MAJOR SPILLS (> 10,000 gallons)
1. Free product may be contained in excavated, lined pits.
2. Contaminated soil and debris may be contained in lined and covered
waste piles.
3. Contaminated water may be contained in portable pools.
4. Contaminated clothing may be contained in roll-off containers.
ULTIMATE TREATMENT AND DISPOSAL:
There are numerous options available to the Incident OSC for the treatment and
disposal of the various waste streams collected from a spill response. These
options vary according to the type of oil, the location of the spill, regulatory
concerns, and proximity of treatment technologies to the incident.
K-3
@ $ o j,
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TREATMENT OPTIONS
REREFINING/BLENDING:
If oil refineries, fuel blenders, or waste oil refineries are located near the
incident, this may be a viable option. Factors influencing the acceptance of the
product include water content, BTU value, debris content, the presence of any
hazardous substances. This option may prove to be highly cost-effective, as
some facilities may give a credit for the oil received or accept the oil for no
charge for disposal.
OPEN BURNING:
Open burning may be a viable disposal option in remote locations under proper
weather conditions. This treatment method is most applicable to contaminated
debris or as a defensive measure for free product in the environment (see Annex
d).
SOIL WASHING:
Soil washing has not been proven on a large-scale operation in response to an
oil spill. Detergents, acids or organic solvents may be used as a soil washing
medium.
INCINERATION/CONTROLLED BURNING:
Incineration is a viable option when facilities are located nearby. A number of
facilities or mobile units are available. However, this is one of the costliest and
most controversial of the disposal options.
Types of Incinerators:
a.
Municipal Incinerators or waste-to-energy burners
b.
Mobile incinerators or soil burners
c.
Asphalt burners or cement kilns
d.
Commercial hazardous waste incinerators
K-4
018
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BlOREMEDIATiON:
Bioremediation has been demonstrated as effective in treating soil contaminated
by oil through enhancement of indigenous microbial populations by the addition
of oxygen and nutrients. The OSC should be aware that bioremediation is a
relatively long-term process that will likely require a great deal of contractor
maintenance and periodic analysis.
LANDFARMING:
Contaminated soil may be spread in a thin layer to allow for volatilization,
photodegradation, and biological degradation. Landfarming should be used in
remote, open areas where groundwater contamination is not a concern.
LANPFILLING:
Landfilling is an option of last resort and is feasible only for marginally
contaminated materials.
WASTEWATER TREATMENT:
Contaminated water will come from a variety of sources during a cleanup
operation. The following treatment options are available to the OSC.
Options for wastewater:
a.
Decanting
b.
Physical or chemical separation
c.
Treatment at municipal or industrial wastewater treatment
facility
ADDITIONAL CONSIDERATIONS
TRANSPORTATION:
Where applicable, transportation of wastes resulting from spills will comply with
40 CFR 263 and 49 CFR 171 through 179.
K-5
0183
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PERMITS AND APPROVALS;
Any concurrences needed to implement any of the disposal options discussed
above or any other technology not detailed will be coordinated through the
state representative to the RRT. Members of the Regional Incident Coordination
Team (RICT) are also available to advise the OSC on any regulations in their
program area and to work with their state counterparts to resolve any
emergency treatment or disposal issues. All the fore mentioned disposal or
treatment methods may require some form of approval or concurrence prior to
implementation.
K-6
0184
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ANNEX L
POTENTIAL SPILL SOURCES
THIS ANNEX IS CURRENTLY BEING DEVELOPED.
L-1
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ANNEXM
MEMORANDUMS OF UNDERSTANDING FOR
GEOGRAPHIC BOUNDARIES
PURPOSE and SCOPE: This Annex contains the existing and
proposed geographical boundary Memorandums of Understanding
(MOUs) between the U.S. EPA Region IV, the U.S. Coast Guard
(USCG) districts, and adjacent U.S. EPA regions.
The listing below outlines the MOUs, attached as appendicies,
between the EPA Region IV, the USCG, and other EPA Regions. The
status of these MOUs are also given
PARTICIPATING ASEKCIBS
STATUS
M-l
Boundary Map for USCG Districts
CURRENT
M-2
MOU, USCG Second District & U.S. EPA
Region IV
CURRENT
M-3
MOU, USCG Fifth District & U.S. EPA
Region IV
CURRENT
M-4
MOU, USCG Seventh District & U.S. EPA
Region IV
CURRENT
M-5
MOU, USCG Eighth District & U.S. EPA
Region IV
DRAFT
M-6
Boundary Map for EPA Regions
CURRENT
M-7
MOU, U.S. EPA Region III & U.S. EPA
Region IV
DRAFT
M-8
MOU, U.S. EPA Region V & U.S. EPA
Region IV
DRAFT
M-9
MOU, U.S. EPA Region VI & U.S. EPA
Region IV
DRAFT
M-10
MOU, U.S. EPA Region VII & U.S. EPA
Region IV
DRAFT
Status as of 21 December 1993
M-l
fl 1 ° <3
V 1 o "J
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appendix M-l
BOUNDARY MAP FOR U.S. COAST GUARD DISTRICTS
UNDER DEVELOPMENT
M-l-1
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APPENDIX M-2
MEMORANDUM OF UNDERSTANDING
BETWEEN
THE U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV, ATLANTA, GEORGIA
AND
THE U. S. COAST GUARD
SECOND COAST GUARD DISTRICT, SAINT LOUIS, MISSOURI
CONCERNING
FEDERAL ON-SCENE COORDINATOR RESPONSIBILITIES IN THE INLAND ZONE
WITHIN THE SECOND COAST GUARD DISTRICT
PURPOSE: "The purpose of thi« document is to delineate the role and responsibilities of U. S. Coast Guard (USCG) personnel relative to
pollution response activities on the Inland River System. Specifically, this document:
1. Eliminates previously designated "specified pons and harbors" on the Inland Rivers within the Second Coast Guard District, thereby
redesignating the entirety of the Second Coast Guard District as Inland Zone, wherein the U. S. Environmental Protection Agency (USEPA) is
the predesignated Federal On-Scene Coordinator (OSQ agency.
2. Confirms the Second Coast Guard District's commitment to meeting the spirit as well as the latter of the National Contingency Plan (NCP)
and assisting the USEPA predesignated Federal OSC to the fullest extent possible in all pollution response activities,
3. Identifies operational criteria under which the USCG will assist the USEPA with its OSC responsibilities by acting as the lead agency and
providing personnel to fill die OSC role for actual or threatened pollution incidents involving commercial vessels or marine transportation-related
facilities.
BACKGROUND: Under a previous agreement, die USEPA Region IV, and the Second Coast Guard District had identified certain geographic
areas on the Inland River System for which the USCG' would, under cettain circumstances, provide a "predesignated" Federal OSC. In general,
in the specified port and harbor areas, die USCG Captain of the Port (CQTP) was predesignated as the OSC for oil and hazardous substance
discharges resulting from vessel casualties or vessel-telated transfer operations. The USEPA retained the OSC responsibilities for all other
pollution incidents within die specified ports and harbors and for all incidents outside those geographic areas. The Oil Pollution Act of
1990 amended the Federal Water Pollution Control Act and imposed new pollution response preparedness and removal requirements on industry
and government, including the predesignated Federal OSC. Hie requirements of die Oil Pollution Act prompted a complete review of agency
responsibilities pursuant to file Act itself and the NCP. That review indicated that the division of agency OSC responsibilities along a
combination of geographic and functional lines did not provide die best mechanism for planning and coordination of current National Response
System activities.
This document redefines agency responsibilities along wholly functional lines that are consistent with traditional agency authorities. It alto
provides for effective integration of preparedness and removal activities in s manner consistent with die requirements of the NCP.
The entirety of the Second Coast Guard District, including die Inland River System within the Second District, ia included in the definition of
Inland Zone wherein die USEPA is the predesignatad Federal OSC agency. The previous agreement designating specified ports and harbors
as portions of the Coastal Zone ia cancelled.
The USCG, through the cognizant COTP, will aasist die predesignated USEPA OSC to the fullest extent possible consistent with agency
responsibilities and authorities. Specifically, for all pollution incidents where there is an actual discharge or releaae, or a substantial threat of
such a discharge or release, of a pollutant into or on die navigable waters of die United States or the adjacent riverbank, the USCG will respond
as follows:
1. If die incident involve* a commercial vessel, a vessel transfer operation, or a marine transportation related facility, die USCG COTP will
provide the OSC and carry out all of the OSC responsibilities, including the decision to direct any neeesaary removal activity or access the Oil
Spill Liability Trust Fund. In such cases, the predesignated USEPA OSC will be advised of any response actions thst the COTPtakea via initial
telephone notification and periodic pollution reports.
2. If the incident involves s source or threat other thsn a commercial vessel, vessel transfer operation, or marine transportation-related facility,
or if die incident involves an unknown source of pollution:
a. The USCG COTP will cany out the USCG's agency responsibilities under the NCP, die Regional Contingency Plan (RCP), and,
when developed die Area Contingency Plans, and will assist the USEPA OSC to the fullest extent possible.
AGREEMENT:
M-2-1
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b. Upon request by the piedesignated USEPA OSC, the USCG COTP will act on behalf of the USEPA in any notions where the
USCG personnel are both qualified *nd physically capable of responding The type and extent of the USCG'* actions in each ca»e will be
determined by consultation between the USEPA OSC and the USCG COTP.
c. If specifically requested by the predesignated USEPA OSC, the USCG COTP may assume the functional OSC cole and cany out
all of the OSC responaibilitiea for a particular incident. The final deciiion on acceptance of the functional OSC role will reat with the COTP
oil an incident-specific baaii.
d. If the USCG it the fsrst agency notified of auch an incident, the USCG will notify the piedesignated USEPA OSC and assist in
assessing the aituation and the need for a Federal response.
e. If a USCG representative ii the first Federal official arriving on-scene at audi an incident, the USCG will notify the predesignated
USEPA OSC and cany out the duties detailed in the NCP pending arrival of die predesignated OSC.
3. This agreement will be incorporated into the agency responsibilities section of the RCP.
TERM OF AGREEMENT: This agreement will be subject to review and amendment coincident with each periodic review of the RCP and at
any other time at the request of either of the parties. It will remain in effect until modified or terminated by subsequent agreement.
Mr Patrick M. Tobin
Acting Regional Administrator
U. S. Environmental Protection
Agency, Region IV
345 Counland Street N. E.
Atlanta. GA 30365
N. T. Saunders
Rear Admiral, USCG
Commander
Second Coast Guard District
1222 Sptude Street
St. Louis, MO 63103-2832
/«/ Patrick M Tobin
/s/ NTSaunden
Date: /a/ April 8. 1993
Date: March 30, 1993
M-2-2
01 s 0
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APPENDIX M-3
MEMORANDUM OF UNDERSTANDING
BETWEEN
THE FIFTH COAST GUARD DISTRICT
AND
THE ENVIRONMENTAL PROTECTION AGENCY, REGION IV
The purpose of tta» Magin a to tMiimafn the gaagiajdii; bcace aook
almg US I7a«fct —t hMlcof Somd; heace «o«h ak^i lh»w« taak of Aftiiiailn Sum! to Sh«e Highaay 45 (NC 4»; hence .out. ak»g NC 43 to US 64. btatx
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APPENDIX M-4
MEMORANDUM OF UNDERSTANDING
BETWEEN
U. S, ENVIRONMENTAL PROTECTION AGENCY - REGION IV
AND
U. S. COAST GUARD - SEVENTH DISTRICT
Tbe iaw of tbia mea»raadum u to debar** eba^ea in hiHgc 14 (amr ffii IbiichI H3Ut OetMpti); tfaeopo xwlhrilji lo US 17 m. mtadma$c 12 (mbt ScnUi Newport. Oooqp*); ttwir n «w*hw!y
to US 341; tbnee nortety to 1-95; tfaeoce MOfaarfy I-9S to tte ianioiiiie of MSO Smanb-MSO JbciamDe HwAn'm XTX'H Wtario «a the «¦« cck* of Gecxffc.
J>cWrviik. Flontk
Tbe OoosMadnc Officer, Marine Stfcty Office, iM^benviDe. Florid». wiQ be tbe |lia 1,1 OaHSeeoe CooRlaMor m tfce jdkwnf tvow wiha Fedeask iUpos IV. WInq
* rmth+y it mei to ikfaiiwftr« booodMry. tfett Uuaurity ilnD be to. b* aiaD act eehde. tbe POMi—y.
CoMttl sreaa from 30^0'N huade on tbe Mt ooaat of Ooorfbi •oaAmwd to 2S*N iMatado cb tbe mat cooat of Fkrida. Lrtilade 30WN on tbe «Nt coMt of OMtybi 4m wb*
to 1-93; tbeace aoitbedy to US 17 IiH » !¦%!. Bccfar, Florida; tbrrr, wMbwIy ikog IIS 27 to Troat Refer Dim. UsKWvilk (Pma M), Fkcida; tfaoca nwiliowiiliily
to Saii Hwy US (FL US); tbeaoe lw*h!; akng FL 113 to BwHilft Avtane; tbeeoe awtlmr^ over tbe idbn MiKbew* Tod Bridgts to Uvvwaty BM; teaeo mitberty to Ft
OtrobcBe Ri«brtji to the awcaiBB utt tbe> SL Jcha Cwty he; U-S, EPA • Rqpoe IV mad U.S.C.C. - Seveslh Diatriet tbaaca tooth
aad weatakng tbe Sl iofaat Coatfy Mat to US 1; tbcace MMtberly to 1-95. iian iiw iaiial alerdsage; tbeace KjObcrty to US 1, Omod By Tbe Soa inerdeaiie; tbcoce aootfacrty
to tbe iauntGkm of MSO JadBMB«3h»-MSO Miami luiianlarj at 28"N laliliak (aeatr f tatiail
ALh> included ia tbe SL ioftai River, iadniiiag alii ifnag tarihhr*. inlamrt to the FL 17 Bridge. PkMv. Fkrida
Miaad, Florida
Tbe CaanDaadng Officer, Marine Safety Office. Minoi. Florida, will be the pndm^gmkd OSC i& tbe fottowtag anaa widnt Fadoral RagiaB (V. Wbea a nwdwy ia wmd to
debaeaKe a booadaBry, tfeal boaadafy akall be to* feat flbftQ *** bdab. tbe nadMay.
Coaatal areai item latiradc 28*N oa tbe oat ooaat of Florida toatbward to ie aorta ru tip of Cape Rooaao. Florida, on tbe wwt oaaat of Florida, aad tbe Florida Key to aad
ocisdng DryTorugaa:
larimrtr 28*N oetbe caatooaat Fkcida (aear Mali>ar) dae weatto US 1; thm'p eaatber^ to Soalb Baydaore> Privg. Miaaa iachdiag tbe Sottb Proog ^haariam Oeektoawaad
to Tower. Flood*, tbe St Lacie River to Port Sl Lacie eo tbe aortb aad Pad» City oatbe aWti, tbe Loaahatebee Sliver to tbe MaiUuaad Mm Beach Cooaty iaae*. tbe Miami
River to tbe N.W. 36th Street Bridge. Mans;
M-4-l
0101
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tbeace aonkwaaeriy akag Sotb Bayifaorc Droi. Mmmi to Caller Road wa MeFariaad Rod Mm K&mmy, b«ntHi> Highly «ad Le Jane Road; teoe •oMbwauHy along
Cater Road to Florida* Tar^ake; tece innl.ilj u S, V. 1071k Anne. Miami (Soak Aikpoth); teco due mtb aio« aad beyood. S.W. ICWth Avow to Imdt 7SWN
teagfaaie mm'W; Ibeaoe wertcity lo Made 25*I3*N. ka^iBrfe »«'W; teoe eertwtaterfy lo the iaereectieB of US 41 lo the immrrhtm of MSO Maai-MSO Tamp*
boundary m «T33*W lo^Me.
Al» iactaded mD be raapaao to ittichiugu or rrlwiri tran cobbkrW top aad/Or lajgu m the laimnJ Waterway (St- Lucie Caad. Luke Ohwehotoe sad Okeechobee
Wmmmy)6vaaemtt Florid* to 81* 30"W lobule (aw FL Hwy 29 Bridge. La Belle. Fkrida) «ad to «*rfroi* tarijoe. along the S<*»i Proog Sekmtt*a Crock, the 3L Lome
River, the Lsniatcfcee lint ud the Masai River to pott» described abowe.
U.S. SPA - Rcfjoo IV and U.S.C.G. ¦ Seveah Diatria
Ttnm. Florida
Tlie Owiinaiiliag Officer. Maime Safety Office. Tufa. Flerife wiD he the predeaipMed OSC in tfca fallowing aroa* wMbb Ftdoal Region IV. When a roadway u wed to
Arhrrmr a bwaadny. that bwanfary ifcaD be to. bis Ml aot ioetate the ro^j
CoMl URaafroalbe asafcera tip of Gape Roaaao.Fiorifc, malMy to 1baiaenoc*Me of the mtaaat of Florida will kaporie CSCW (moahoftbe FeahoUowny River):
Fro the nttnrtim of Ac M cm* of Florida wife lo^fade n*J0"W {attt of the FeafcoBoeey River) 4m aortb lo US W (laeraoOMc of MSO Taap-MSO MoWe
boaarfaty); teee eaauaty to US 19 mti Akenate 27; thence **«berty to FL 361; fence ¦oaherty to FL 358; teoe waneri? to US 19 and Afcemae 27; teee aonfaariy «o US
19 aad W; ten aMla# aloqg US »to Akrale US 19; ten aMfea^r lo FL 697; these* uMfcarty to FL 595; tees aortberty to FL SM; teee aaauri? to FL MS; tec*
toaheriy to FL MO. thearr i—rriy to 22ad Aveaac Scab. SL P«»OTbi*j; thence eaiteriy to 4th Saw Soah. Sl Pambori; tece aortberty lo FL M7; teoe oortbtrty to FL
684; thence naaariy to US 19; thance auithealy to FL 590; thence i—mtyto FL 580; tbeace raarrrty to FL 176; thence inatirfy to FL 589; thence eualmlj to 1-275; thence
aonheriytoFLS»7;teren1irri)rtoFL«5;tei=«anaiertytolheCiMiama«l<|»B«eaay, TannlW i iMtliwialj toUS41;lhiani imlmt/to US301; thrnon awlheily
to FL 675; term eoahariy to FL«4; teee U.S. EPA • Refioc IV aad U.S.C.G. -Sevaafc Diwrittwawiy to US4l;tecgao«ba«lyto FL 7ft thence inifr to FL 31;*—*
aoMfaariy to FL 80; tfaeaca aawly to US 41; tbeaee aotfberty to FL 78; tbcwpe aaalcrty to FL 31; Hwi eottberfy to FL 80; teco wnatedy to US 41; tern wbarty along
US 41 to tba 'MtxwGkm of MSO Tamfa HSO Mkni botery at 8TWW knppafe
Ako iadaded wffl be napoox to dK^rgea or idaatoi tna viaimifii jail op and/or barfca in tbe Itfmoaahl Waenwy (Okachotoe Wmenmy) fnm tVX'W kaptade (aear
FL SMe H«y 29 aridfe. La BaOe, Florida) Mariy to tbe (Mf of Meneo.
M-4-2
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APPENDIX M-5
MEMORANDUM OF UNDERSTANDING
BETWEEN
THE U. S. ENVIRONMENTAL PROTECTION AGENCY, REGION IV
AND
THE U. S. COAST GUARD, EIGHTH DISTRICT
The purpose of this memorandum is to establish the geographical areas of responsibility for the predesign*ted On-Scene Coordinator (OSC) for
pollution responses to oil and hazardous substance discharges pursuant to the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP) and the Oil Pollution Act of 1990.
The Regional Contingency Plan (RCP) and Area Contingency Plan (ACP) of the signatory agencies will be amended to reflect die following
geographical boundary.
1, The Coastal Zone boundary begins at the intersection of the southern limit of die Right-of-Way on US Highway 98 (US-98) with the Captain
of the Port (COTP) Mobile - COTP Tampa boundary (83°50' West Longitude). The intersection is twelve (12) miles west of Hampton Springs,
FL on US-98. Then, westerly on US-98 to St. Marks, FL, then southwesterly along US-98 to the junction of the John Gome Memorial Bridge
and the north shore of the Gulf Intracoasul Waterway (GICW) at Apaiachicoia, FL, including Ochlockonee Bay, East Bay, navigable portions
of East and West Bayou, Blounts Bay, Shoal Bayou, and Alligator Bayou.
Then, continuing from the junction of the southern limit of the Right-of-Way at the John Gome Memorial Bridge aad the north shore of the
GICW to its intersection with Alabama State Highway 59 (AL-59). Responsibilities include: East B*y, St. Andrews Bay, west Bay,
Choctawhatchee Bay, Santa Roaa Sound, East Bay (Blackwater Bay), Escambia Bay, Pensacola Bay, Petdido Bay, and Wolf Bay.
Then, north on AL-59 to its intersection with Interstate Highway 65 (1-65). Then, west and southwesterly along 1-65 to its intersection with
US Highway 90 (US-90) near Theodore, AL.
Then, westerly along US-90 to midstream of the Pearl River, the boundary with the COTP New Orleans.
U. S. Coast Guard fUSCG). Eighth District:
COTP Mobile is the predeaignated OSC for pollution responses in die Coastal Zone. All discharges or releases, or a substantial threat of such
a discharge or release of oil or hazardous substances originating south of the boundary line
will be the responsibility of the USCG. Included are discharges or releases from unknown sources or those classified as "mystery spills".
Additionally, all discharges or release* originating from waterfront facilities within the city limits of Panama City, Fort Walton Beach, and
Pensacola. Florida; Mobile, Alabama; and Pascagoula, Biloii, and Gulfport, Missiasippi are die responsibility of die COTP Mobile as the OSC.
U. S. Environmental Protection Agency (EPA1. Region IV.
EPA Region IV i* the predeaignated OSC for pollution responses in the Inland Zone. All discharges or releases, or a substantial threat of such
a discharge or release of a oil or hazardous substances originating north of the boundary line will be the responsibility of die EPA. Included
are discharges or releases from unknown sources or those classified as "mystery spills".
a. The EPA and USCG will accomplish their agency responsibilities under the NCP, RCP, and, when developed, the ACP. Each will assist
the designated OSC to the fullest extent poaaible.
b. When requested by the designated OSC, die USCG or EPA will act on behalf of the other agency in any actions where personnel are both
qualified and physically capable of responding. The type and extent of the actions in each case will be determined by consultation between the
two agencies.
c. If specifically requested by die designated OSC, the USCG or EPA may assume die functional OSC role and cany out all OSC responsibilities
for a particular incident. The final decision on acceptance of the OSC role will rest with the requested agency on an incident-specific basis.
d. The first agency notified of such an incident, will notify the designated OSC and assist in assaaaing die situation and determining the need
for a Federal response.
2. General.
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e. If a representative other than the designated OSC i* the first Federal official arriving on acene it an incident, the representative will notify
the designated OSC and cany out the duuea detailed in the NCP pending arrival of the designated OSC.
3. Boundary line* and limits of responsibilities do not preclude assistance between the two agencies.
4. This agreement will be subject to review and amendment coincident with each periodic review of die regional, area, and COT? plans and
any other time at the request of either of toe patties. It will remain in effect until modified or terminated by mutual agreement.
Date;
Patrick M. Tobin
Acting Regional Administrator
U. S. Environmental Protection
Agency, Region IV
Atlanta, Georgia
Date:
lames C. Card
Rear Admiral, U. S. Coast Guard
Commander
Eighth Coast Guard District
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APPENDIX M-6
BOUNDARY MAP FOR EPA REGIONS
UNDER DEVELOPMENT
M-6-I
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APPENDIX M-7
MEMORANDUM OF UNDERSTANDING
BETWEEN
THE U.S. ENVIRONMENTAL PROTECTION AGENCY REGION IV
AND
THE U.S. ENVIRONMENTAL PROTECTION AGENCY REGION III
The purpose of this memorandum is to establish the geographical area* and limits of responsibility for the predesignated On-Scene Coordinator
(OSC) for pollution responses. Responses will be made to incident! involving oil and hazardous substances pursuant to the National Oil and
Hazardous Substances Pollution Contingency Plan (NCF) and the Oil Pollution Act of 1990.
Regional Contingency Plans (RCP) and Area Contingency Plant (ACP) of the signatory agencies will be amended to reflect the following
geographical boundaries.
For the purpose of emergency response, a portion of the regional boundary « changed. The common state boundary of Kentucky, North
Carolina, Tennessee, and Virginia remain unchanged. The state boundary of West Virginia and Kentucky will remain the same except for:
1. The boundary ia delineated by the Big Sandy River and milage markers published by the U. S. Army Corps of Engineers. Beginning at the
confluence of the Ohio River and the Big Sandy River, Mile 0 (Zero), hence southerly to Mile 10. From Mile 10 upstream, the normal boundary
remains as die river centerline or as the geographic boundary.
U. S. Environmental Protection Agency flEPAI. Region IV:
Beginning at the point of Mile 0 (zoo) of the Big Sandy River, hence southerly to Mile 10. This section of die Big Sandy River will be die
responsibility of EPA Region IV, to include all response action necessary and/or required to the water line on die Right Descending Bank (RDB)
of the river. All discharges or releases, or a substantia) threat of such a discharge or release of a pollutant originating west of the water line
on the RDB will be die responsibility of EPA Region IV. Included are discharges or releases from unknown sources or those classified as
"mystery spills*. Additionally, EPA Region IV has responsibility for:
a. Notification of downstream water uaen.
b. Coordinating with the Ohio River Valley Water Sanitation Commission (ORSANCO) for other notifications and warnings.
c. Notification of EPA Region V and U.S. Coast Guard (USCG) Second District.
d. Assuring notification of downstream water users of a spill when properly notified of a spill by EPA Region ID.
U. S. Environmental Protection Agency (EPA). Region M:
Beginning at the point of Mile 0 (Zero) of the Big Sandy River, hence aoutherly to Mile 10. EPA Region Hi has the responsibility of all
discharges or releases, or a substantial threat of suds a discharge or release originating east of the water line on the RDB. If a discharge or
release reaches and/or enter the water, EPA Region IQ will be responsible for die response effort. Additionally, EPA Region HI has the
responsibility for:
a. Notification of downstream water uaers.
b. Notification of EPA Region IV of a spill when it has, or there is a threat of a spill crossing the water line on the RDB.
c. Notification of EPA Region V and USCO Second District.
d. Coordinating with ORSANCO for other notifications and warnings.
2. General.
a. If specifically requested by EPA Region IV, EPA Region III may assume the functional OSC role and cany out all OSC
responsibilities for a particular incident. The final decision of acceptance of the functional OSC role will rest with EPA Region ID on an incident
specific basis.
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b If EPA Region ID it the firit agency notified of a «P>H we*1 of water line on the RDE, EPA Region IB will notify EPA Region
IV and assist in asaesaing the situation tod determining the need for a Federal response.
c. If an EEA Region ID representative is the first Federal official arriving on scene at an incident crossing the established boundaries,
the representative will notify EPA Region IV and carry out the duties detailed in the NOP pending arrival of the predesignated OSC.
3, Boundary lines do not preclude mutual assistance between the two agencies.
4. Previous Memorandums of Understanding or agreements are replaced by this document.
5. This agreement will be subject to review and amendment coincident with each periodic review of RCP and ACP and any other time at the
request of either of the patties, ft will remain in effect until modified or terminated by mutual agreement.
D*ted: _____ Dated: ______
Patrick M. Tobin Stanley L, Laskowski
Acting Regional Administrator Acting Regional Administrator
U. S. Environmental Protection U. S. Environmental Protection
Agency, Region IV Agency, Region DI
Atlanta, Georgia . Phils delphia, Pennsylvania
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APPENDIX M-8
MEMORANDUM OF UNDERSTANDING
BETWEEN
THE U. S. ENVIRONMENTAL PROTECTION AGENCY REGION IV
AND
THE U. S. ENVIRONMENTAL PROTECTION AGENCY REGION V .
The purpose of this memorandum is to establish the geographical areas and Emits of responsibility of die ^redesignated On-Sceae Coordinator
(OSC) for pollution responses. Responses will be nude to incidents involving oil and hazardous substances pursuant to die National Oil and
Hazardous Substance* Pollution Contingency Plan (NCP) and the Oil Pollution Act of 1990.
For the purpose of emergency response, the common regional boundary is the Ohio River, and is described as:
The boundary is delineated by the Olio River and mileage markers published by die U. S. Army Corps of Engineers. Beginning at Mile 317.2
(confluence of the Ohio and Big Sandy Rivers), hence westerly to Mile 981.2 (confluence of the Ohio, Lower Mississippi, and Upper Mississippi
Rivers).
V. S. Environmental Protection Agency (EPA). Region IV:
EPA Region IV is responsible for discharges or releases, or a substantial threat of discharges or releases of a pollutant from a source originating
from EPA Region IV into the Ohio River. Responsibility begins at the water line on the Right Descending Bank (RDB), extending to the south.
Included arc discharges or releases from unknown sources or those classified a "mystery spills*.
U.S. Environmental Protection Agency (EPA). Region V:
EPA Region V is responsible for discharges or releases, or a substantial Ihreat of discharges or releases of a pollutant from a source originating
from EPA Region V into the Ohio River. Responsibility begins at die water line on the RDB, extending to the north. If a discharge or release
enters the water, EPA Region V will be responsible for the response effort.
a. Both regions have additional responsibilities when performing duties as die OSC. Included are:
1) Notification of:
a) Downstream water users.
b) -.no River Valley Water Sanitation Commission.
c) U. S. Coast Guard Second District.
d) U. S. Army Corps of Engineefs.
2) Notification of each other when a response event has occurred or is anticipated.
b. Either Region, when requested by the other, may assume the functional OSC role for t particular incident. Ike decision to accept will rest
with the Region being requested, on an incident specific basis.
c. When a Region is notified of a discharge or raleaae, or a snhstantisl threat of a discharge or nieaae of a pollutant not in its area of
responsibility, the Region will notify the responsible Region. The reporting Region should assist in assessing the situation and to determine the
need for a Federal responae.
d. When a representative of either Region is the first Federal official arriving on-tceae of a discharge or release not in die ana of response
responsibility, the representative will notify the responsible Region. The representative will accomplish duties detailed in the NCP pending
arrival of the predesigaated OSC.
e. Boundary lines do not preclude mutual assistance between the two agencies.
f. Previous Memorandums of Understanding or agreements are replaced by this document. Regional and Ana Contingency Hans of the
signatory agencies will be amended to reflect the response boundary.
General:
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g. This agreement is subject to review and amendmentat any time, by requeat of either party. It will remain in effect until modified or
terminated by mutual agreement.
Date:
PATRICK M. TOBIN
Acting Regional Administrator
U. S. Environmental Protection
Agency
Atlanta, Georgia
Date:
VALDAS V. ADAMKUS
Regional Adminiatiator
U.S .Environmental Protection
Agency
Chicago, Illinois
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APPENDIX M-9
MEMORANDUM OF UNDERSTANDING
BETWEEN
THE U, S. ENVIRONMENTAL PROTECTION AGENCY REGION IV
AND
THE U. S. ENVIRONMENTAL PROTECTION AGENCY REGION VI
The purpose of this memorandum »to establish the geographical Meat and limit* of responsibility of the predesignated On-Scene Coordinator
(OSC) for pollution responses. Responses include oil and hazardous substances pursuant to the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) and the Oil Pollution Act of 1990.
Regional Contingency Plans (RCF) and Area Contingency Plans (ACP) of the signatory agencies will be amended to reflect the following
responses boundaries.
For the purpose of emergency response, portions of the regional boundaries are changed. Tlie common boundaries of Arkansas, Louisiana,
Mississippi, and Tennessee are established as shown in:
Section 1. Lower Mississippi River (LMSRV), Mile 828 to Mile 504. Boundary common to the LMSRV, Arkansas, Mississippi, and Tennessee,
Section Q, Lower Mississippi River (LMSRV), Mile 504 to Mile 305. Boundary common to the LMSRV, Louisiana, and Mississippi.
Section 01. Boundary common to Louisiana, Mississippi, and the Pearl River.
Section IV. Boundary common to Louisiana, Mississippi, and die Pearl River.
Section I, The boundary is delineated by the LMSRV and mileage markers published by the U. S. Army Corps of Engineers (USACE).
Beginning at die point of Mile 828 (intersection of the regional boundary between Environmental Protection Agency (EPA) Regions VI and VH
on the LMSRV), hence southerly to Mile 504 (intersection of the state boundary between Arkansas and Louisiana on the LMSRV).
U. S. Environmental Protection Agency. Region IV:
This section of the LMSRV will be the responsibility of EPA Region IV, to include all response actions necessary and/or required to the water
line on die Right Descending Bad: (RDB) of the river or the levee of die RDB. All discharges or releases, or a substantial threat of such a
discharge or release of a pollutant originating east of the water line or levee of die RDB will be the responsibility of EPA Region IV. Included
are discharges or releases from unknown sources or those classified as "mystery spills*. Additionally, EPA Region IV has responsibility for:
a. Notification of downstream water users.
b. Notification of EPA Region VI and U. S. Coast Guard (USCG) Eighth District.
c. Coordinating with die USACE for other notifications and warnings.
U.S. Environmental Protection Agency. Region VI:
EPA Region VI has the responsibility for all discharges or releases, or a substantial threat of such a discharge or release originating west of the
water line or levee on the RDB. If a discharge or release reach and/or enter the water, EPA Region VI will be responsible for the response
effort. Additionally, EPA Region VI has die responsibility for:
a. Notification of downstream water users.
b. Notification of EPA Region TV and the USCG Eighth District.
c. Coordinating with the USACE for other notifications and warnings.
Section II. Continuing southerly on die LMSRV, starting at Mile 504 to Mile 30S (intersection of the state boundary between Louisiana and
Mississippi on die LMSRV).
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U.S. Environmental Protection Agency. Region VI:
This section of the LMSRV will be the responsibility of EPA Region VI, to include «ll response actions necessity and/or required to toe water
line on the Left Descending Bank (LDB) of the river or to the levee of toe LDB. All discharges or releases, or a substantial threat of such 8
discharge or release of a pollutant originating west of the water line or levee of the LDB will be toe responsibility of EPA Region VI. included
are discharges or reieasea from unknown sources or
those classified as "mystery spills". Additionally, EPA Region VI has responsibility for:
a. Notification of downstream water users.
b. Notification of EPA Region IV and USCG Eighth District.
c. Coordinating with the US ACE for other notifications and warnings.
U. S. Environmental Protection Agency. Region IV:
EPA Region TV has the responsibility for all discharges of releases, or a substantial threat of such a discharge or release originating east of the
water line or levee on toe LDB. If a discharge or release reach and/or enter toe water, EPA Region TV will be responsible for the response
effort. Additionally, EPA Region IV has toe responsibility for:
a. Discharges and releases identified as the responsibility of EPA Region IV in Section I that may enter toe Section O area.
b. Notification of downstream water users.
c. Notification of EPA Region VI aad USCG Eighth District.
d. Coordinating wife the USACE for other notifications and warning*.
Section ID. Continuing from toe water line or levee at Mile 305, LMSRV, hence easterly to toe Peari River. This portion of the Louisiana
and Mississippi boundary is changed only from the intersection of the boundary and center-line of toe Pearl River to toe intersection of the
boundary and toe water line on toe RDB of toe Pearl River.
Section IV. Continuing from toe intersection of toe Louisiana and Mississippi boundary and toe water line on toe RDB of the Peari River, hence
southerly to the southern limit of toe Right-of-Way on U. S. Highway 90,
U. S. Environmental Protection Agency. Region IV:
This section of toe Peari River will be the responsibility of EPA Region IV, to include all response actions necessary and/or required to the water
line on the RDB of the river. All discharges or releases, or substantial threat of such a discharge or release of a pollutant originating east of
the water line on toe RDB will be the responsibility of EPA Region IV. Included are discharges or releases from unknown sources or those
classified as "mystery spills". Additional responsibilities are toe same as for toe LMSRV.
U. S. Environmental Protection Agency. Region VI:
This section of the Peari River, EPA Region VI has toe reaponsibility for all discharges or releases, or a substantial threat of such a discharge
or release origination west of the water line on the RDB of toe Pearl River. If a discharge or release reach and/or enter toe water, EPA Region
VI will be responsible for toe response effort. Additional responsibilities are the same as for the LMSRV.
a. Either Region, when specifically requested by the other Region, may aaaume the functional OSC role and carty out all OSC responsibilities
for a particular incident . The decision for acceptance will rest with toe Region being requested to perform the OSC role, on an incident specific
basis.
b. When either Region is notified of a discharge or release, or a substantial threat of such a discharge or release of a pollutant not in its area
of responsibility, will notify toe responsible Region. The reporting Region will assist in "**»•"?£ toe situation and to determine toe need for
a Federal response.
General.
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c. When ¦ repreaentative of either Region is the first Federal official arriving on-*cene of a discharge or release crowing the response boundary,
the representative will notify the responsible Region. The representative will accomplish the duties detailed in the NCP pending arrival of the
predeaignated OSC.
2. Boundary lines do not preclude mutual aasistance between the two agencies.
3. Previous Memorandums of Understanding or agreements are replaced by this document.
4. This agreement will be subject to review and amendment coincident with each periodic review of die RCP and ACP and any other time at
the request of either of the parties. It will remain in effect until modified or laminated by mutual agreement.
Date:
Patrick M Tobin
Acting Regional Administrator
U. S Environmental Protection
Agency, Region IV
Atlanta, Georgia
Date:
loe D. Winkle
Acting Regional Administrator
U. S. Environmental Protection
Agency, Region VI
Dallas, Texas
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appendix M-10
MEMORANDUM OF UNDERSTANDING
BETWEEN
THE U.S. ENVIRONMENTAL PROTECTION AGENCY REGION IV
AND
THE U. S. ENVIRONMENTAL PROTECTION AGENCY REGION VO -
The putpose of this memorandum is to establish die geographical treat and limits of responsibility of the predesignated On-Scene Coordinator
(OSC) for pollution responses. Responses include oil and hazardous substances pursuant to the National Oil and Hazardous Substance* Pollution
Contingency Plan (NCP) and the Oil Pollution Act of 1990.
The common regional boundary is the center line of the Lower Mississippi River (LMSRV), For the putpose of emergency response, the
boundary is described as:
The boundary is delineated by the LMSRV and mileage markers published by the U. S. Army Corps of Engineers (USAGE). Beginning at Mile
953.8 (confluence of the LMSRV, Ohio River, aod (tie Upper Mississippi River), hence southerly to Mile 828 (intersection of the regions!
boundary of Environmental Protection Agency (EPA) Regions VI and VH, sod the LMSRV).
U- S Environmental Protection Agency. Region IV:
EPA Region IV is responsible for discharges or releases, or the substantial threat of discharges or releases of a pollutant from a source originating
from EPA Region IV into the LMSRV. Responsibility begins it the water line or levee on the Right Descending Bask (RDB), extending to die
east. Included are discharges or releases from unknown sources or those classified as "mysteiy spills".
U. S. Environmental Protection Agency. Region VH:
EPA Region VO is responsible for discharges or releases, or s substsntial threat of discharges or releases of i pollutant from a source originating
from EPA Region VII into the LMSRV. Responsibility begins st the wster line or levee on the RDB, extending to the west. If a dischsrge or
release enters die wster, EPA Region VH will be responsible for the response effort.
General:
s. Both regions have additional responsibilities when performing duties as the OSC. Included are:
1) Notification of:
a) Downstream water users.
b) U. S. Coast Guard Second District.
c) USAGE.
2) Notification of each other when a response sweat has occurred or is anticipated.
b. Either Region, when requested by die other, may assume the functional OSC role for a patticular incident. The decision to accept will rest
with die Region being requested, on an inodeot specific basis.
c. When a Region is notified of a discharge or release, or a substantial threat of a discharge or release of a pollutant not in its area of
responsibility, it will notify the responsible Region. The reporting Region should assist in assessing the situation and to determine the need for
a Federal response.
d. When a representative of either Region ia the first Federal official arriving on-sceoe of a discharge or release not in the arse of response
responsibility, the representative will notify the responsible Region. The representative will accomplish duties detailed in the NCP pending
arrival of the OSC.
e. Boundary lines do not preclude mutual assistance between the two agencies.
f. Previous Memorandums of Understanding or agreements are replaced by this document. Regional and Ana Contingency Plans of the
signatory agencies will be amended to reflect the response boundary.
M-10-1
DRAFT -
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- DRAFT
02 0 3
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g. This agreement i» uibject to review and amendment at any time, by request of either party. It will remain in effect until modified
terminated by mutual agreement.
Date:
PATRICK M. TOBIN
Acting Regional Administrator
U. S. Environmental Protection
Agency, Region IV
Atlanta, Georgia
Date:
WILLIAM W. RICE
Acting Regional Administrator
U. S. Environmental Protection
Agency, Region VII
Kansas City, Kansas
DRAFT -
M-10-2
- Do Not QUOTE or CITE -
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APPOTOIX N-9
MEMORANDUM OF UNDERSTANDING
BETWEENTHE
ENVIRONMENTAL PROTECTION AGENCY
THE UNITED STATES COAST GUARD
AND
THE GENERAL SERVICES ADMINISTRATION
PERTAINING TO THE
Federal Respone Uadcr The National Ofl aad Hazardous Substances
PoBntioo Coatmgener Plan (NCP)
I. GENERAL. Thw Meaoraafaai of Uahnasdiag (MOU) i»|Ba tbt t*mnl mimitm of die CM Sarvicv Admtmomem (GSA) to pmide kcMad sad
taocannaareaxgi rapport to the Fatal! i—HwIiimt. Th TTTTf ajm ifirnH)' "lull " fir -r|i -iiritiiirr *1*1 m |ii «li wmni Tn flu Fin' in 'mrU rr-rnnimi ri|i mi j
(EPA). tbc Uaad Xm Coaa Pari (USCO) —1 aher a«iab«ic offc HtTtB*»Mai«alOa«ai HCTntaa %haa1» m PaBHoa* Camwgacy Pfca (NCP) who wooM
toa»ll»Jbylto(EPA/USCGfrFodadOa^«»Co«*aa«r(FOSe)ia«»«l»«a»liBaioal»>l nWNCP. ta fcxtbtW (mntamto t» fcfe~ed by EPA. tte USCO.
meaW^rcKMofthcNKT.Bd OSA wfeanckMMDc. i> nqaaad Id iaw«t tha» ftai. Tie MOOJm reagan. tfca tbe tgrney providaj tfc> FOSC sal/or aaabcr
«|hii im nf tlir fTT mn f ' f-r ifi iirtiiiiii in |«ininl^ imli mi—ni
II. BACKOROUND.
i«tii«I»hIbii i" rwnl— wife Ac Naioatl Ofl «nd Haatrdoqi
ii*ti»» u°s!
A. tla F»l—I Biin—ir.
Mam«» NWa Cmmpacf (NCP). TW t
ariLai^Aaafca>ii>aofdaOilMakaAA. USCO. lb EtafMMaorMcaM (SOD), ortta ia>sr (C09. i> lk>f«raw *&M»aai cwnW^ d atarcOxtt ate rae
of — ofl or turnliM 11*1— I Bin. TW uaco frowJe. FOSO for eg «¦< laifcamiiaBce nil—m iaaarte—iaasfc 'mail tamct SPA [irtnMa the FOSC for
hi I m. im «¦» or tk—< the atari Me. POD ari DOB pvritm FOSCi for tommy fccsfity or vmmsI opMMMl wfitt tknr mpttctbtm jWMdbctKii or ooHbraL
of ISFodaalifwci«iialli awjnr aa»ira—tad p^ic ImMi ra|wa«flifliri«
fatal arfl—doa artwai i r a> of npoal in^aaau n htm «acfc 3tm wUm tbe Kapoa ni an uu-dwiial by EPA aid USCO. Tk> UtT> «m m
I before ¦ rimmaii.—itel *ar ifaafra «fcy ni|iin ifaari a «al mMoiUp IW FOSC a MOU » Coaasdat (O-MEP)
B. Repoal Offioa. TW piiaifl fan
IV. PRINCIPAL OS* STAFF
A. GSA ITanrrf y Ciiwiliaam. Tk» fiaupal poia of eoaact Ha
I OCkm* (BPA/USCO).
official ia GSA Caaal Offica m ths OSA nimtfry Coordaaor
B. Rrgif 1 Eaafaaej rnniliaaii. For¦ ap* iIuibap
doagattd almaai it tfcc tafiovl poia of oaaact for tifiiail imfamt Ta
tko FOSC «iB dmct *e GSA REC a> to i
mini «r wtttmI merycBcy Ins via mi til. Ik* GSA EMVgwe^ CMnKMtsr (RjBC) or •
1 (RKt) Co-Ctar aim aal raqaoa* for naaa. On tkt tmmfmey twfmm m mdxrmmy
C. F«i—I fiaiiff iry Swpport Caartmmm. UpoawaiatsrnqaMtforaaaaaco feoateRRTCo-Clair ®PA or USDS), *• OSA bpal Adaaiamr or
« dulnaiut Ii|niiaaiiinaan^faa» Fiiail liaofary %fim fi'iham (FBSO> Tbe FBSC AJ «or»» m tfa ptac^ol pim of „ taaaa fl >au naOSAoa* FOSC for
tbo i^Hnhiiia of tr^ixiraj mm piaraia. «»ii.aiia of OSA wonrca. «a» n iili—iw o( to alt&Q&A. mrwiom. i ,|ii|iaia. lad ¦airiiii «wfna«|iiiiaian
K»irl»- aaairaiw. f>»FSSC.ii»tt.fywnia.OSA<^|WHaag» y*»FB3C..M ¦maaffy b«kaadatteFi^IOffic« TV. FB3C wB arwfl riJa..J
by tte FOSC.
r for 1
r(ZECP)> mZSCFi
I (DOf) or ofmiaa wS • OSA aaff fan wk i
»MtT»8l ii I
iatioZaao Raiiii—"y
E. Foiaal Ha.|.aj r " T i Ihafir. | ' , ' —
¦ MaaprlMJCkQw i
The FSCM wj caaaa to «a»» m*a lap «j aai —fca
wMi ifftoptim OSA a^ppeit h (hMnwl hy tte FBCM. vii aoMMBjr In kahd in Iks RoU CNSot.
V. EMBROfiNCY CaCUMSTANCBS.
itOMtoUMbtbeRaUOfBcvMCctetoaMl
(tonhanbi «falaK«nteM/oi tpi
C ¦tWi j* Him of tke CinpirMf ¦ Co*arti«f A«t of I«*i wilh'Wi'
wwiMt el irrtwa V1JL3 of Ait MOtl w£ b» fiaicNwd to «aar»
ccMjriiHMW wMi cwpirwBMfli. Dbcwomi m> to At of
narlfan of wftacy mfainil fat OSA i^|i,il ma be aai» by tfa FOSC. wHk tb» ttrice of FBSC. Vatal
r nfaatlat OSA <
tiaNo»Vataae
¦ MiBri. TW FBCM,
¦J b» luiiaai m m m i«a»
N-9-1
0203
-------
VI. CSA RESPONSIBILITIES. Upoo reqaeet or —by the FOSC CSA stall provide a Ml range of txmeiy logtsbcal end teiecoamaacabooa import to the Federal
respoaee effort m accordance with Federal Acquwtioo RcpMon (FAR), the CSA Acqaeaiou Rcgateoa (GSAR). as amevfted. sttl idc»ei» potofcc law* so th« the Field Office
may be epenbaml do later tin 48 how* alter the requ* n tecctvod by CSA.
A. Space —
1. After the FOSC has determined specific space reqtaraacas tad operational facility Deeds for the Field Office)s) and other required srq^ort locations. CSA wtD
expedkiousiy tiiaugt for the ok of such space, la airier to provvie CSA with Ju.mii itmim to support is n—initial ofctogaboa. the FOSC will provide to GSA. wttgn 48 hoars
of any verfcal request, a writtea josbficaboa for the size. type, approximate daaion. aad locaioB of the rcquwtid spKx. CSA will ae aD available sources. Sbse and
local goverwneaj. to obaa eppropriae space.
2. h ii Trlmtrmd that sparr riwpan uiiih luaji ibaugi ilni'1 rmrrfrnryprrinrf If the FOSC determines that aa increase or decrease is space for the Field Offict
is reqwred. it wiD provide CSA with 14 day* prior aobce to acqaire the now space. Is each cam. baraae the 'tarnion of a anal or '-^T»fl"lg urgency* to east
aad market survey reqairemem may stiD be vuived. GSA wiD expedite the search for the myail oew space.
B. Office Pleasure aad Tii|ui|mim. To allow for the tiaely opeaog of the Field Office)s) or other loabons. the letpami office fuutiao aad eqapaea will be
provided from «o*ca tha wiD be tiaely aad provide the least coat to the Cum laiiial Sources ased caa be excess or aapia tsvcaohc* of the Federal Guvuimm. if available,
or by lease or pauhasr froa nrnmtrrial sources dctermif»d by OSA to be ia the Oovmft'i best Arrest.
C. Office Supplies. Office s^pies aad other expendable jfteas wiD be provided from either OSA or rranarri ial soarces. If from i iiiiiwii sal soarces. bhafaet
jwa i lasi tfr*rnriyf (BPS's) shoedd be aflird with local veadon adeas aanthrr method is dctenaiaed to be acre nlia^agiima by the ';,y officer.
A BPA shoold be ased with local nadon for pa-chases ader $25,000. The FOSC or his s^pert. Tie FOSC alert shall iadada a tad caahoa. trgaliril raqbraaaaM. aad the poaaal ana of the opsnban to enable CSA to afca the e
aDow for the expediboa «pag of the field office a eota m poaaAle after the i
Z Emttfmey Opaetfkns. Upon iaptsaeaeaboa of eaergmsy teapoase cparakas. the FOSC wffl rafaa the OSA J
provide specific tagatfiad export a^ adade a tad dauaon aahamag OSA to on^wt oa behadf of the FOSC forthoee goods ad eavka r
wftsch aay ber***"* ^ the ibbal raqast is iaauad varha&y, it wS he oaabraad ia writiag witha 24 houn. a a aactasa (1). He i
i of the dagrea of agaj a^ the tanalasa rapa ad far piuvibun of OSA siypuiL It wiD also indade. if needed, the basis for a jn
i to be aade by the OSA oaamcbag Officers) ia accordanoe with FAR 6.3Q2-2(cXl). which aahoraa other 4an "M ad epau ooapatibea' a oaaa of "
ooapefliag agency.' The FOSC aftar ocaaftag tha FB9C w# detoraiae the tas after w^ach aoaooapaative ao^baiboa an ao kager be jaMifiad. AD OSA cuiiali
exocaed
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3. CoonSMDoo of OS* Servian
1. To am Ml OSA nppat to the FOSC and the emm Federal Maibdncel involved m * ipeeifie eaeifeaey reap»e eff«t aad avoid tftoM of napeata
(or ktvicm. oqupmett, or ^ermk. the FOSC win TOyn* "4y» logubct coordg^or i/»(jy>ut«a»e- All ipecific agency mfitmm CorlogatKal
.appt* wD be to the FOSC. tbragh » logiitio eoordi«*cr. then to the GSA FESC.
2. To iacwre the ellocawaee. of CSA» teaponaa caphiliy. R8T Co-Oatr» «wfl enure that GSA laadqfrti n and GSA nyoMi office*, aa aiyoptaae. ire avtod
to panaciprte with sanberi ofthe «T m phaaiag —I opwk—l mi 'tup tha involve or garnet on the OSA *iynil area. of rcap«a»t»lity. Sort nioeeag mctade. bet ere
not batted to. ptaro« mecUqt. vynaaoMl iiinitiiii. and po«-omj'giacy cmtgor. Cope. of repem reflcrtan on the aarvkee of <354 m Report of nyeamm of tSmt MOU
will be fonwded to the GSA Emefieacy Coonhaaor.
3. The ayagy the FOSC aad OSA luitniancti agree to iwxfcto twain an—lug logialiial rapport uvx* th* arc referred to the hflifurttn level,
h ia expected that the FOSC. the FESC or other apprepraae regitMal agency officah vd OSA itgaoaal official* will natos every ««tra»pt to naclve iMata at the Field Office and
Regional Office level* prior to farwaidtag «acb iaeaea to laaiilipaifrri for reaelttiott.
4. FOSC wiB mb accoaaaUay lor aD fmaton. office asl other wpjpmtat aad ntiali kaaed or rested by GSA for reapobk mda the NCP.
The FOSC win a»n«ae reaponeibaay for the mmatimBMX. md nfmr of abased for
mda farta&av mi in|ia)n il y nan to the vaadtr.
5. Far the parpen of sKaatonf the arthraiad ripialilian and hi iliadiag liaMiy A» laimlioo of proevaaeM nn»mt recta*, the FOSC agraa to review
penaboaDy wife the FSSC the order wlan placed adcr BFAa.
C. CSoaag the field Office
1. At the time the Field Office k mrtlialnl the FOSC or barter daagaiaad rapraeeaMive win give the FBSC aad the F8CM m aMa of hoar bag the Raid
Office wiD ranaa opea. aad will aotify ten ia a toady Mnaor of wsf chaage is tlat aMMMe. The FOSC »a provide wriaaa aotice to the RBC *. Inr thmi ewdahrye before
cMag the FieM Office. Enaftaa iadiartarf a VI.C.2 below. OSA «apport to the FadanieMrgaaqritapaaM vaaonMBjr otaaoapoadcMPOoftha Fiaid Office, at wWch taae
all Aattaer Iqpatkal »»d S«aeiil Mffoit via he provided by ^ FOSC thr«*h tl» amal opanliag procednrm Asy active coMactal agnaaaaMa ead/or emogaMaa fcr iervice
raqwed bf the FOSC ate the doaiag of th» FteU Office *ffl bacaa* tha M r-p»«*y of the FOSC or «haraeniieaa°-a«r«4aimted
aad SaalUaehorid he aarhad'FINAL* Aiy ytooadnaa or mailiMiia -Ta«Uianl ia i laaaiy will he agreed ^ea by OSA Mdtte FOSC aad affljadMifoftjUo aachagfcy't
mpicttvt ngsoMl office! to allow OSA to c
2. OSA RdataeeaeB. For rosbaraaMe iiiihimiii it acari ia <^i|aaliiig aay aoivaaea covered by tfcai MOU, OSA w9 otan raobaneae* (mat the FOSC
thread the Pna»«ii« of die Tieaaau'eOa-yae PajwM Ml rollariwaa *ji— (OPAC) GSA wiB mdiMI, OPAC Mfc ^tirty earl e«t*y with tha prwaanai of «« CFB.
Fait 205. SahpaKl. RoaiLamwa of Other Frderml Ageaciae. to tha «*aath* thay are audi i, alili GSA Mlaho jeovide copiaa of the Had werhaahoriiMioa report or anlar
docoBMtMbMO to dMxfy tfae 0?AC cktegHKt. B3b wfi pacify xm|mhI for mhnbkc to ni^kirh tkey ffT^y. tit iMdap 4ocvBHMtioi v2 Mit ilant by obpcK dwi
aad eat ctcmoa and aaB iadife (a} [nwioaily Mad. (b) carta* Whg. aad (c) .auiidaun ataoiaa Mkd to d«e.
3. Re^ochag. ThaagMcy ^rovidatg tha FOSC agxaaato MaiiMSiaa^r a^wail reposttag re^tareaeMfort^pert ptwalad hy OSA. Ay woBrila^ai aad I'tjwtiag
liaddCFB. Fart2ttS. Mi|iaH I. wiB be coanared apoa by OSA ^ Aa ageacy ia -iiala» the FOSC «th» haadfaatota law!
B. AnUm. WhM to to by providl^ dM FOSC tfac O&k UM^odor Caxvsi (1G) wfi« ok ft nsiBhwmUe Imi». Im( coaereb wad by OSA
ia in MBfaf |jiu.ufca— mmk tit nienii Wb tfrt Q3A d to FOSC to ilrtuniii milwrtwr they ggpruyutj fyanwL Tkm OSA K? oaanrit witti At
FOSCca^vacy QBtheioBiaHiaai of tfetcop»
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B. Item^c^condiatooffe^c^froifidatteFOSCartfhirdaipBaditpTOMMmaBlfeGSABMteaejrCMrinaiKahdamtMaKtMiy.
10 IW» «HKM
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appendix N-10
letter of agreement
BETWEEN
U. S, ENVIRONMENTAL PROTECTION AGENCY - REGION IV
AND
II. S. COAST GUARD - SEVENTH DISTRICT
AND
STATE OF FLORIDA - DEPARTMENT OF ENVIRONMENTAL REGULATION
PURPOSE
The parpoaa of tfcu Later of Agnoacac " to provide pre-coaaafeMKin lad mauaiiaix for tfce attbtxiMMa of baud mc of diatrniam aid atar cfcnmcaU oa ail apilla by
prMaaigiaiad USCO O&Scac CoanHaacr».
AUTHORITY
Snlopmt H of&o Nrtioaad Oil md Haafdo— m Ciiafiiin»j PWnpro«^ tia*tfc>Oa^caa»Coorin«or»iltitfccc«ocama»cc of the USEPA ii| «i -etatiio Eogifl
Rafaw Ton nl ia eemlMMB Ml the Smh, aay "Ptfiiif the aw ofad other dboeak N«waal 03 aad Haaanloaa
taMni III rm in I III / ykBto—jwrireinoof ili»|inMm aad otWr fciaiali far ooMrol of afl ipja. »d. to li« «*idt laf 11—i aad caber chmiirak wtach —y ta> Mod for
tlw pSfpOMS.
SCOPE
The USOG. USEPA aad the Sate of Florid* agree tha lie physical tvmml of djurtarfaf or apfied oil fam the aaier earfcee a the [liwij ae*hod of uMiU. Hoiww, k
it aieo that ib soaae iatiaacae the phyiad GoaBaaneat Bad coBeetMB of ofl ie iafcaabfe, aat, the e£fecth*> aee of daparaale or o&er ehe&acah auat be coaaidafadto
miwMTMTfl earioae cavgQBawaal daiwye or to prai 1 iaa of haaaa Mle. Thwifi.ni, till Latnr of AfTBaaeat ib— criteria —lor abi A diepewaae of other ehankab a— be aeed
fay USCO Os-Sceae CoonfiaMton oo or is vision off tto comC of tin 9Mo of Floridh vfeidk on aiio wriwjt dn bovnlMFMi of Sws^fc Comc Qwd Diitnct.
PROTOCOLS
A» mmtd lob^iv apffwci set (aA Mow. ib USEPA ad 4k 9m» of Floridi apw) mift it USCO te piMlnpMd U9CO 0» Scow Cooriwion fam pu fpri^ml
lo mc (bftntfi ob oil tiidMia, at dofisod ¦ tie NMkal 03 wmi Hmrfai SdMaoM CoM^eacy Pta. ¦ accorteB wtt i» foAow^g. Tk U3BPA ni Ik 9Me of
Floridi ftMtfaer agree «itb tie USCO tlal the decawn to dHperaatts or OttMr claakiadf 11mm iwUbbs r««s sakly pr»-deafattd USCO Ob-Scw C iriam waalar.
1. Pifiwaah or ether rhwirah aay be a—d oa aB dadary Mtm their a*e will mm haaat ife. The fettewiag addibcaai i, i—ftjtirai aa—w »afc to haaaa life a aot
« factor.
2. Tbe«almay to aw* dapewaaa or sAer ulwaucah oaoil Jin.ha|,ui a ai i nihia i withtti» Altaic* a veaed aaialy m the jadiwdial *ho a the pra^oapaad USCO
OarSooae Coonhaaor. Tla aa^oricy mmy aot be dokpaed.
3. Dapenaati
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CANCELLATION
Tfau Lata of Agnosia my be tm-rlltd m vifaie or m pan. nag&aty- >9 **t W thereto,
IISII Mm A. Little. Depo^ for
CteriM R. Jeter
Repotmi Ailnm»«i«r
U.S. GmriMBcal fnteakm Agaocy
Rc*»a IV
mi! 9/5IU
IIS/I Qkgitfc
Victor* Tsdaakod
Secmtmy, Fkrifc Deptna* of .1 i»rettaicl
m/i mi im
* DqcmmnK CofMii For Otty
N-10-2
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ANNEX N
INTERAGENCY SUPPORT AGREEMENTS and
MEMORANDUMS OF UNDERSTANDING
PURPOSE and SCOPE: This Annex contains the Interagency
Support Agreements (IAGs) and Memorandums of Understanding (MOU)
existing between the U. S. EPA Region IV and the various federal
and state agencies found through out the Region.
Only the IAGs and MOUs most pertinent to response efforts are
listed in this Annex. As other supporting IAGs and/or MOUs are
developed, these will be incorporated into the Plan through this
Annex.
The IAGs and MOUs contained in this Annex are presented as
follows:
N-l
USCG-1PA
Mitigating of Damage to the Public Health or
Welfare Caused by a Discharge of Hazardous
Substance.
N-2
USCG-1PA
Mechanism for Funding Vendor Costs Incurred by
the USCG During Emergency Response.
N- 3
DOT-EPA
Re-delegation of Certain Pollution Response
Functions Under CERCLA.
N-4
DOT-EPA
Instrument of Re-delegation, Executive Order
#12580.
N-5
USACE-EPA
USACE Support for CERCLA to EPA.
N-6
DOD-EFA
Responsibilities for Executive Order #12316.
N-7
ATSDR-EPA
Policies and Procedures for Health Activities
Related to Hazardous Substances.
N-8
EPA-DOI
Preliminary Natural Resource Surveys.
N-9
EPA-GSA-
USCG
Federal Response Dnder the Rational Oil and
Hazardous Substances Pollution Contingency Plan
(NCP). Under Revision as of 12 November 1993.
N-10
EPA-USCG-
FL
Authorization of Limited Use of Dispersants and
Other Chemicals.
N-11
TVA-EPA
TVA support to EPA
Ji-1
0211
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APPENDIX N-l
MEMORANDUM OF UNDERSTANDING
BETWEEN
THE UNITED STATES COAST GUARD
AND
THE ENVIRONMENTAL PROTECTION AGENCY
Mitigating of Damage to Public Health or Welfare
Meaoraadom of Uodentudag betweca the EoviraaBeraaJ Protection Afcscy aad the Uoied Smm Cob* Gtard Coaccraiag the Mitigating of Damage of the Pofatic
Health and Welftre aimed by a Disctaage of Hazanioui "iJiMbu i mder Section 311 of the Omn Wefter AcL (33 USC 1321).
Tbt U.S. Con Gmti (USCG) aad the Eiwwucari Proiecboe Agoary (EPA) agree thtf the rwpoasibflity for the nibg*iaii of damage to the pobbc beakh tad
welfcre ceased by the discharge of kumiua sobMaeea ibaH be ifrarril by the USCG aad EPA Ties Mcmortatfaan obtttln pobey omuenaug the reapoanUkie* of the EPA
aad USCG mauling mibgmioa actio*.
SECTION I
GENERAL
Secboa 311(b) (6Xc) of the Qeaa Wmer Act. ¦ namtiiil. amhorized tha Admivmar of EPA to act to v| ' the dMage caoeed by the diecba/gc of bazaniooi
Mteaeti. The cot of obgaboo »bafl be deeaed a n minal coat iatard vder eacboa 311(c) of tha Qaaa Water Act.
Through Executive Order 11735 (or a* aateaded). the of the Pneida* pnniad to Secboa 31100). (A), ratbag to the tMmfaiiehoMtt of arthndi aad
procedures for the waoal of diacbavgad ad aad haadoui e^smacee. ¦ detepaed to both EPA aad USCG.
IV «aaan ad mtm far wfckh each agsary has reepoaeibiity are defined ia the Nmknl Oil aad Haiarioa Sabemacae Ma'ai coaBageacy Pin (40 CFR Part
1510. Secboa 1510.36(b)).
Acoardiag to the Nmmai Comiageacy Haa. EPA is respaasibie for iabmd Mien aad the USCG is reepoasiMc for coaMl «*en aad the iam. ports aad harbor*
of the Ore* Lakea. Theee geographical area* are father defiaed ia appicatic R«gi naal Catageacy Pteas.
SECTION Q
COORDINATION
Ia accoi^ace with the piwdaagMed gaagtaphiaal anas of raspeaahSfey. EPA aad the USCG agree to wdertafca approprime mibpboa acboas of diei laiye of
fanardom safeamacee witfe each agcary's defiaed ana of raapoamHfcy.
The cost of each mjbpbea acboas tUl be ooamdered a cot of ifuial iauaiad aafcr sidan Uta (c) of the dean Wsarr Act aad shall be reaabmiable thiowgh the
311(10 revotvmg lad.
Mjbgm>oa efforts iaciade. bat are aot kimiled to: adnribas each ae oottanammeaevee; aeaswee reqmrad town aad perfect the p^dic of acmetager, aebvibes
accessary to provide sad aMaiterthe qarifey of tsa^onry drarioag *atarsowas; jaaahariag the ipnad of the puflutam; faMaaaitorisg todeterB»e the ejgam of the coaaoaiamMa;
phyeical mcaiaustoideattfy aad oamm eah^mcae oo^Ma—d by thediecfaaga; prowidl^ aavigsboaai camioa wtaflc reepoaee tothey aMiia is iln^ay; efforts to rmee —hea
vessels wfcech are tha eovce of tha diecfargc; impfaMMbaa of aaatjeaey tnaactf faciibee; aad aay efforts accessary to iocde tha eoaree of the discharge ad identify properties
of the polhbas discba^ad The lag bra sohaiaa to maay spfls may be the ooartracboa of major capstoJ awtam, iadadiag advaaead Matt symeme or ettsaeioa dikas.
WUe each major eaabwboa may «aft mab^e tha daagar to pahfie health or welfare, they are aot appropnmr mitigabaa acboas «dar Secboa 311(bX6XC).
• Qui mm Copied For Refer*** CMy •
N-l-1
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APPENDIX N-2
MEMORANDUM OF UNDERSTANDING
Between
THE UNITED STATES COAST GUARD
and
THE ENVIRONMENTAL PROTECTION AGENCY
» » *
A Mortrom for Fiofiag Vcafcr Cm
PURPOSE:
Use U.S. CoMt CM (USCG) aad the Smkmmturnk Fwtecttoo Agcacy (EPA) a*re© that ¦ mr-hm—m » nptd to tad USCO eoatt mtmi tevg emofcacy Rspm*c la
itlniM, or the ttreala of rrlnaaw of kttffkm iiiiiu i or jwlhaaaa or oo
Fmdm$ for ox-of-pockic ax^jimna and qdwr nrm 'i-frfiw eaati hotbc liijuii of a lopatf ifrwaeai bormn tibe EPAawl tfca UaCG.
The Crntt Gmtd twtt adviae all of to Diane! Cammmiam, pwdaaiftad OahScaae Coortnaiori (QSC), aad Rtfimat liiwaMti Tmmmtmimn of Act— of Hai f tianwaalieii
The USCO wtQ prwi^o to EPAa eorMii«i^| of Di*rkt par»o«ti who wfl aarva ae apfroprMto o«*ct for EPA oa ¦rttera ratateaf to oo**cta* aad acoo«B*j fer rwpc««
acoviy.
CONTRACTIHO AND ACCOUNTIHO:
The USCO wad the EPA «fm that the EPA wSk pHbra all accommag far vaarfor oo«i.
The USCO a»t the EPA agme that the oa^»ct^«yi>——d by tha USCO far wpOBMatp Md hiTardni wh^peAachfowdar the a*hor«y of Sactiai 311 of tihe CSorb
Wolor Aau thaQ heaaad far USCO mapoamm to afl rabnaa* orttrafei of ralaMae of taoMdow «dMnp«« orpdhaaaBi or coahMaMti aa dafi—d m CB8CIX.
Any ccanarti far iinnMitiii> iommI adMaa ia rmfoam to nkamm or Hi1— of nlnni of haaadaaa aakmaam or polhMti or oottHaMb ontBrad iato by the Coatt Qaart.
where the USCG OSC ic aetiaf m 1ha napar-il)1 of fim napoadiac Faiwral. olEkad. pannaal to the Natkaal r niriinx ji Plaa. ahafi twaaaa m tMaet oaly danaf the pariod that
the USCO m the OSC.
Aa^f caatract for saBBadjaaa mmmak aodcaa ia raagaaaa to lalaaaaa, or tihraaaa of raiaaai, of haanftoaa wabtmem or foBobaKi or oo^rnamaam, oaharad baa by the Coat Gaacii
Hainan to the arttenty daiaplad viar fiaMOMiva Ofdar 12316, aad maaad by tha 11900 « SkM (c) of tks lailnHaaK of Ra^ifafHMa. inn-Med 2 Octobar 19KI by the
Secrcavy of TfaaajntWiatt aad ooaaaMai 10 oa 9 Octobar 19tl by tha AdaaaiMnAor of tha Emrkvrnmmi hutodka Afeacy. atafl nmam m adBEacc oaly dng tha period that
tha USCO ia auiat mder thria arihanQr.
The USCO aad the EPA agiao m tha faflowi^i ai far oooKdai«a« tha EPA aecaatia* tymm md the USCO wadiaaiag ajaioai.
1. OtaBKoiacanfaar. For aaA 'mridtm wb*aa CERCLA ftadi art obh^ed. tte USCO OSC —at ofaa^ a la» digil iituaM iaiwhar SPA Hailif ten wkick
at'laMiifana a apecifiu atte/apM aasida^. l\o aasdaar ia obaaiaad hy obttas-'
Chief, fttapoaae Openbcai Hiaiib
Office of EaMryoKy aad "RoaMMhai RaapiaH
EsviraaaMaad httodka A$aacy
401 M Street. W
Waaki^ua. DC30M0
omm-nn
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The USCC OSC will pwide an ettaate of the reepooec com corcomtoi* wih tte leqaeet for a aroom amber.
The te*^djgS accoat number will act be anaed mieu CERCLA h**i* are available for the reepcaai! action.
2. AccouOBag code*. Specific arrraaiiug mformabos u reqaicd by tte EPA Fisaacial Managea»ea* Syvtem m order to proceea reepoaee cum act. There are five categoric*
of accouttiog and coatroi wwhm which mot be eaered on each ¦«< fi—docractf- Tie arc:
• AfiproprM&oo Naabcr Tlae nobcr m penmesfy assigned to the trat fed.
68-20X8145
• A
aag wih at (1) and aala a aoariaoa oa the leat iavoioe oder the ceoract with the phnae "FINAL INVOICE*.
4.2 USCO OSC I
- The USCO OSC —t certify each correct aad proper iavoice. A correct aad proper arroke ia oae in which the oanricoe performed are accepfcMe aad a
with the eervioee bflhd aad the i ^ag *a property UuaftiJ The i alifn «i.a eaia i e to he aeed by OSCU of both ia for aB CERCLA aad oeapiaMly aahottad.*
- Tie OSC will faaaid by certified aafl dhi au apail aad oertified invoice, within 72 boat of receipt of the iaveiee froa the i laiailm. to the EPA payag office
(addnaa abm above).
- The USCC OSC ahaD NOT certify avoicaa which iadade diacnpaacia* hataaaa eerwcee parfiaaeil aad iuimi haBed. fa the wvwM, that thare are iliai a ii|am iai
ia the invoicea, the USCO npnacMive ahaO. innediataiy ^oa main °f ^^aneiai actaaa to aotify the aad to mdw the 4
Wtta 72 hoan of receipt of a irvoice coMoag i—ai>el iliai mail ia, the OSC ahall faaaid the svoace by ceitified aafl to the EPA jnyag office (ad^aaa ahowa above).
The arvoece wiD be eadormd with the fnjnuii aMeaeeaft:
N-2-2
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•n»i «*OK* tareactved Aampaaciaa. DO NOT PAY THIS INVOICE UNTIL YOU RECEIVE WRITTEN NOTIFICATION THAT THE
discrepancies have BEEN RESOLVED AND the invoice is reissued.*
QSC T- ¦—*
4 J EPA RwpaonTjiitM:
-TheEPAtatherapwlxfyieiiroetaecwsaisroiceeadionriBeoaCiactpayiigeaaiBaaBxiyBaner. Coma jmymaa are BOfBUlly mtie with JO dayi
ato iwoke ««*"*•
¦ PiymtM- will be r nitimim ¦» Opeaaionn Bnacfc
Eotryiacy Ruyonat DwiaMB
Office of S»M|iacy ami tiwil fagot
EninMl Pntectiea Afaacjr
401 M 3dm. SW
Wnahingtnn, DC 20460
<203312-21»
Tha USCC wffl nxxkfy, aa mi—), ay enathag tatact to redact aach liling iocnnaa. CeRifiad of the eencmct mndifirarir* aal he anTaiWTiii tothe EPA hying
office.
TV USCGand EPAreoogazetha CE&CLAtaqveethat raaponeeacthaa ceaaewhoaSl sffieB ia Migm* or tuaha hawe alajaed frnathedae of Mnl taapanai, except
aa aahnraed nailer Socboe 10t(cXl), thereof.
REPORTING REQUIREMENTS: POLRHPS
Tfce USCG and the SPA agiae tha the SPA. aetata tte cepacia m aaaigerof the Iiaiad» SifeBao* Rii|ifii Trat F™i. reqva 4ie inrtaiiaaina m CSJICLA
f«tx>wai*MMarf lb totaled otiip«io» of CBtCLA tab tor th»a0M. Po—iaa jtepoWa (POLREPS) era eahaaed by USCO Oac.lo USOO D*nct Cnnmlii 'i.
POLREPS provide fatfnal apeeaboaai dttk nhttig lo a telnaiee a oaftna ncoo^aaag of prejact com. Tlaa USOO 09C vA enhatf a dnpMoaa copy of all POOfcEP*a to tha
Director. Emmgrncf Roapoaae Dwiwaa. EPA. (TWXP710-C2MW) far the papcee of Ma« Cg»CLAii«y« ^ fit nW^ali .i *»«> BP A. TkaUUPOLKBP
viS ho tatf nMtta 24 hom of iatiiiiqt a mpovo aetiOB. if iafmniiai ia aiwilafcin. OMCothoaicU ra|—1» oonplalad. prap«M POLABPSaiortl he an* o» a pok»b hew.
PERIOD OF AGREEMENT:
Hii y'mxii—*»» ffnj cmnimb is offect mtil ®orfifiBd or ¦¦mmInkI hy tfas ima of both pirtMi or loisiBMMl by tiltor (30) Mdhwe wriBMB Mlics to
the other pity.
Nothiai tutfcia agrawaia imded to Uaik or othanaw affect tha awncry atfhorky of tha afacn ianatixd.
Tla« M—uiaatiia wil baco»a egeccve a» a«a m ihe of the It aifB»» heio«.
//S.'/ W. E. OMmmH
W. B. CALDWELL
Rear AMnl U.S. Coaat Oasd
Chief. Office of Haiku Eauii'ianatf nd Syatona
iron 12/io/si
DATE
/ISII Chinofar 1. Otfptr
CHRISTOPHER I. CAPPER
Office of Sohd Waaia a^ Ea*»««^ Raay*
ma u*m
DATE
* PocmmI CcfitA Fa lUftrHn Oaiy *
N-2-3
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APPENDIX N-3
INTERAGENCY AGREEMENT
BETWEEN
THE DEPARTMENT OF TRANSPORTATION
AND
THE ENVIRONMENTAL PROTECTION AGENCY
Redckgatioo
Is accordnace wih Section «(F) of Eseative Oder 12316 of Aagatk 14, 1981. te SocnMry of the DcfMaal in wkick Ihe Cm* Goad a ayuaiug hereby ndelcpta to tbe
AdnuaaMor. EovroooKBi] PraectioB Ajcocy (EPA), object to the AdanwB*°r'» comm. <11 fmiaa •peciSed m SecKa 2(D). 2(F) < 2(G). 3(A) *B) of tbe Exsosve
Onicrwilklhee«c*pMBoftbe feBowaj:
A. Fi«»aioci rd««d to lo or tbrct of rtiat. frcm vomHi;
E Fttiani nhtmtlo ianedil raao—1 «atoo cSim C ¦ .fir (OSC) deMnroe tba weh aaioa —I be Mfac 11 ¦*»» tbe «nr>»l »¦ ir—i of « EPA 0»3eM» Ciuiiigal ¦ (Jaiaaa ofterain ipwl
by EPA tad USCGtlai «k**y wfll sat be exenieed aafcai tie EPA OSC it nMM lo irfiw <«<**«*¦« 4# him of sotitaMB of Ike rotaeee or Are*
For r«ptm of tla inimr the tcta •jiiwinll naonl adiaa* ibcMm Mg> raaoval action mbirh, n «i» of tbe USCO OSC. i
niirnwi imttiHim aad a|ie(i <¦ barmlo^am life or bnath to tbe mil !¦¦¦¦. arto rml or (manual ofl-te property
ba on Ml farted to. fire, upioaioaa, aad after aaddea rckaaee, ban. aaaal. or food ckam ctpcman to ¦
AO faaetMM deecribod a tbia ianM. whether »«h legato! or —1 ' brWr th* uabonQr to rn— rt for, ob%rte aoaiea for, aid atm-»»n anaage for Md imliil the
• Docatf Copied fee ItofcnaoeOiiy *
N-3-1
021
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APPENDIX N4
instrument of redelegation
1. -Eicqeieprowied below, eecconleKewiihSeetMe ll(g)of Bxeci«ivcOnl«r meof j»e*y zs. nr. the Saamty of the Departmett m wfecti the Cm*
Garni a opening beieby dilemma to tbe MaaMs. Eavtrtroeaai Protect** Ageocy (EPA). ratject to tbe Adaiaamtor't coaaa*:
»- >11 fuoakn (pacified is Secbeaa 2(f), 4(C). nl 5(b) of ite Eiecww Older, cad
b. (fee fisctioaa apecificd m Secaoaa 2(i). 2(30. 200. «¦* <* ** Exeeaive Older to tie tarn th* tfcae faction relate to tbe fooctxm rpeci£ed is Sttam 2(f)
of that Execmve Older.
2. Tbe tocMM tmiekpted aader tbia Imiiaiu of RcdetopOoc do not iacMe;
a. fmetfcm irfctad to reapoaaaa to rrlnaaia or team of rdm Irtaa treaaek;
b fmatam rektad to fern "V «**» """—in wlmn or tl»ti of tefaaaee m. bc&tim other tin active <* iaKtivc *ta*ardoBB *a*e naiatiu fccSt**" (*•
defiaed is 40 CFR 270.2); md
c. hmcbom iiiKmii to amity km hi iiii trie— m or Hi Mi of iiiaaaoi « actio* or iaactiw "bntafaoi wmu mmgi in m fcc&iea* mkm Ibe Cm* Goard
On-Scene n (03C) Iwwiin ita« aacfcaaioa —j to pw or
ei
'.xpioaom
4. AJ1 deocrilwi a tiai docMac*. »ht*brr rokfcfa«d or ratMaai. Miadc tbe Mabnnry to coaaraa fcr. Mgmc
for, ad ottierwiae anii for aad i ni»ili—. ike rmpamm arhdwl ««bi» each faactieat.
IIS// JmiBnanloy 11X311 WTSm
<*«!)
Secretary of Tropeataxai
I hereby caaaa* to tbe tfililnrtno aa —t fart in *¦ a
IIS/1 Lee M. Thorn* mil tmM
A iliiaiaawmir. Ban imiaiinaal ftotactioa Ageacjr
* ni.li, taiieM Copied For Refmce Oaly *
N-4-1
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APPENDIX N-5
INTERAGENCY AGREEMENT BETWEEN
THE VS. ARMY CORPS OF ENGINEERS
AND
THE U.S. ENVIRONMENTAL PROTECTION AGENCY
IN EXECUTING P.L. %-510,
THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION,
AND LIABILITY ACT OF 1980 (CERCLA)
PURPOSE
Tb> EumumnJil PiuMOiub Agpmey (EPA) tea mall —iimy rafmittxy fcr i
of]MO(CESCU).alMkMMa*Sa|wM. TK» agnaamtke i
1 Response. CdapnMiflB nd LiehQiiy Act
> to U.S. Aim? G*p» of Gapmn (Carp) tM prorate is EPA
background
t. CERCLA pronto —burifr mi I
Older 12316Macs fnmrf nup—MBy htm
kagcr tarn (rumifaft urn at aitai
b program.
i of tfcfi fa&aftMHg: i
Btion ad ntafeod
. 1073. 1092.
ihe frtMtm mi wheta oct-clfcawa r—dial acbon; ftad imaga; «ed ¦
}. SUM* say partem aO or pa* of Itof
4, Tbeaahoriliaa I
et acq,, and Sogimb 21$ of to Flood Coftral Actof 196S, P.L. »-2». Titf. 2, ?» !
EPA'S RESPONSIBILITIES UNDER THIS AGREEMENT
1. EPAwffli
Cfltpt tCOBftB ft |
2. EPAwBfranfeAaCiayivMariBciMiMHClsaMMaflhiaclniNaaomnilgrttiiVMaat. IteCapaHMwSaMt
«*irh. at a mimmmt vffi ooMroi —d—iaMa nH^lo Cap i
3. EPA will
CORP-S RESPONSIBILITIES UNDER IMS AOREEMBHT
Iteamad Eaecaivt:
i ipb Med •*» mI
i*p dafin the n ntl—, ftesiVTiy «adyfc> mali—i
> to EPA i
n^Wy^n^rplMi. This a
, iiu—Uui f aad oponte. The Coips aba «£ aa
¦ agreed tfOB-by the a
», EPA'* i
itomtkfy
t EPA is iukii of SMtomsBqpd ptyjeOt m So
19y*otm.
selected by SPA far Corps
the
openie. EPA wtD set
«ih EPA'» overml
of in
9BB0l^raHd pPQ^piHI* CSSfpS
X EPA i 11 ¦ 1 IMK
Corp will we to own atonal pneaim
eet«aeidee wifl he m aeoeriMM «ih the a*rm Mt «* a the
3. Corps Dinwa E^nvart «d SPA n%i«l AdMNMsr*
4. Hi apgtMi fttafl he a0Kth*i far i of tw yvn. il wtff he viodified«
or ib the iaarMt of the Mtiosd <^£eaee this he tenBiMted
FP8 W-T06-SW.
piwii>y» t£ thii muni— T^amxSWao*
or liiaijMiiil by —1 of*» pni«». lac
5. Tbo Cmp and EPA wffl i
N-5-1
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AUTHENTICATION
Thu mgrtamM will become effective iqx» RgsaOre by i-ifr pu*m
Aonc M. Goivacii
Eswoaneaal Protection Ataxy
IIDII Ou Olefibk
/ISJIAmc M. Gomich
WOtaB R. GaadH
Aimx Seaatry of the Amy
(Civil Wort,)
mil 2/3/82
//SI/ Wfflaa R. GiudK
• Doom* Copied For Refract CMjr
N-S-2
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appendix n-s
MEMORANDUM OF UNDERSTANDING
between
THE DEPARTMENT OF DEFENSE
AND
THE ENVIRONMENTAL PROTECTION AGENCY
FOR THE
IMPLEMENTATION OF P.L. 96-510
THE COMPREHENSIVE ENVIRONMENTAL RESPONSE,
COMPENSATION, AND LIABILITY ACT OF 1980 (CERCLA)
1. PURPOSE
The Pn-iUDta of Defene (DOD) tad the EovtraBetol ftwaaiau Ar"7 (IP*) m i*o tin an«m«tf to drily mcfc Aftucy'i rarponwbflioe. ad mmrtmmi
for cMBduaim and fiaadm rmptmt makm aahorrad by ike Coafntewc SkriraBaaftl Ciiuim—niuti. mi Lmbfi«y Act of 19S0 (CERCLA) ad ipeci&ally
ddegvcd by Eieaove Older 12316.
Tbu»jt»ca^dot» pot trirkplf. mtf i'«|»aaili1—ICT* ¦ ,ii— -n.. .. » m* , , ! ,li hit >i i nf t».JW~. P—.i.y .„y ou.rvr-ni
- At DOD'ireqaeataad cm diecnlMB. EPA will pronde DOD mrbairal iairy»iftMiadviiaf> nab. Thi>»«aa>4ot*>ofH^'torat—>Mfar^tecb DOD ¦ act > fMyoMiUtj jmty mder maim
107(b) ef CSROA («.(.« " "infjr
b. ^lii ri mrr ln iftiM nirfc nffhriifj
Wbui tbwv m oB-htSty «
pvtydcM»K>. AC DOD'* i
C DOD bol^f is tti Mb mnm« DOD v9 ooadHct Mil f
»lo DOD «r «ar«« in a (rihfiaory rale.
Wbaa tbara ii off-boHty so dnf twUnesthM 4 DOD fccflfey is tftpaoiB Mwca, BPAiwl Saaswaatf octihasiawwil^pliwii >ad MmImc df*fccfity lo d
ttoam^tM^ibMaMaiaariiieaMiaMMpcaNaG^ D0D«S &mk»asicc«4kxaratagaboai oaAtDOD i»ci*y tod
—d HM oftim etjmmmmticm madlhincammmiadrmpcmm *xim, POP mi PA aitt rnm iliKi fkme aSrnm md n—jjag >»ar Wri to ¦¦¦¦«» sem
6 aB rcpsMi, i
If* ftftar DOD BPA rwMw fAaaa wHifibQMi* it mi dkManvaad tlHK At canratf> DOD fccAty it An mIa #owob o
wmmv tbf ambw frty doa» wad iwi iMwbiii EPA far cwtt EPA ipaaitd ¦».
If. iftcr DODvi EPA miw Acae i
Idii'Mii Ibei
t of two or i
DOD ooad** aad fianc* tb* raapoBM
iflfiiMMiM EPA aad DOD joa^r
3.2 Rokaaao Freaa For»or DOD PacSbai.
N-6-1
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I. Rdeaaee frna faw DOD Facfl***, when DOD it the eoie npnie pet-
it EPA. in cMMtaoon wife DOD. docramn tlx > Conner DOD fcciBly » fee •de met of fee cmamiiinn. DOD wD fiance any rtaponae action. mcludn^ off-6^tlity
itafMaae ¦enow, or will mi te anakcr pmy one of two or sore naponeible panm.
If EPA. a conralMion widi DOD. dAaaH feat DOD ii «e of two or mare partiee mponaiUe far fee a—niiiikg EPA *wiH contact and fiance fee raeponae action and
EPA. in conMiMion wife DOD. wfll dacnatae fee a|n»uy.ine napese carta. DOD "ill ««nnl*a(ae EPA fe> aaoM.
IfEPAagnxa. DOD may eteoae la conduct fee raayonee action. If EPA condacta fee traponKaaxa. DOD wig raafeiaaefee Fad forfee AcMb. IPA conewrcoce » re^arod
before DOD otadaaa ¦ rapome action.
la caaea where DOD wife fee daennitaaion of wapwitaiy. propoaad action, or in cat. DOD i
3.3 Ofeer ReiaaKe for Wfafcfe DOD ia a RaaponatUa PMy.
: fee dvpoal aoiaion auction of fei» agreeme*.
Whoa thtrt ia a rel—e for winch DOD ia a naynwiMc patty, and which doaa act mniw a cam or former DOD tuaSly, EPA will iawnrigaro fee need for a nap in action,
and fee Kam of ny flatty Of iifferoa partiei for the reioac, mdoda* DOD'a faapoaaiibihty* EPA. a Iiiirtwimi w«h DOD. **S Aftnae the appropriate roapoaec eorti
aod DOD will teiabarae EPA that aaaoaat. If EPA agree*. TOD may choam to nwhrt the iif >jmk tdiai lor tie paaoa of the rnlwat for *4acb it is rraynatfNr. EPA
a isMfiiud before DOD awrtati t mpmet maim.
. DODmd EPA wiB jotaHy tmiaia ihe»o*ap|*u|aitt0naptaai!,
i of riafiiiaaTalky. pmpmed adrau or * coat, DOD nay me the diapote neufcum aactNa of fifai*
Far ittrae ra front DOD 1
la caeca where DOD diaagreee *Ah the i
4. FUNDING OF RESPONSE
DOD wiD
prngma are
to pay for mpa
Dad by the DtptfMt v
rai otter eavvaasaaBU faKjecfei i
I piiyn
¦r OMB Grcaiar A-106
DODinti
What EPA imIiiwIih a ri apr—n far whicfc DOD ia I'miiianililii mdtr CESCLA. DOD *4 ¦
inbvMBMl, DODaeTf year badgat mpMt will |KWb a ra^aaH lor Fa
as tifcuog the paMoalar t&rce'of upprapriHOem for psyaMaS by 0k gowaBaal, <
VbnMavat
IVui iaiu— id. (Mi ipMM (or ptymi* by DOD
i «r 31 U.S.C. 72te.
AnrcouMofMi is nfeject totfce of appropnateHB.
Each Agcacy wiO man raconJb of all ccati iafciaiad «4kb aay avoive pajaiian to of front to Fadi ad wffl jwiiwda 4
t of tinM) com m. tim attnr Af^aey'i
5. COMMUNITY RELATIONS
Wkm EPA vaiMloBi ¦ rwyon ortioai, SPA wiB be tvapoaaftia for «
Snporfwd Piragnm (Put IH, SwtMW 4).
i pujfiMB far ie wtt. at ipactSwl ia Ike GMnn for
Wbea DOD oa^MteloBi a fMpoiNB ai.tifi, DOD vnD bo napoaaSde for oslonaaCMB to the local ooasBaMBtfy.
For bfA aad DOD acboia A tbc HSko bFA aoi DOD wiB ooadact a joas oflcaaattHt^' roifltMait pro
6. EXCHANGE OF INFORMATION
DOD aid EPA ««& excbaajc iafm laalim oa a npiar baai*. EPA and DOD wifi itfom «di dGber de oarikaC peaatte aiafe of «ay widwrr of eaatoantfiaa. ^rpec of
EPA aad DOD wffl fcaap od«r iafu—d rapudiaj tfa» type and avatiabOiiy of dafc or Saeb or ¦fmaaiiw wffl be
t» Agwybail ¦! or paa> rarww. tfpnai raipfaart fnliriiai Agwrjtarbaral nrjMW miaiii TTnTTaart Hfft ^iTI tahiir tbafh (4 >pnrifir
r for fwiaw. Rawiew ooaaaMMMi wH bo aibbnaaad ¦ fiaat t
Agcaey I" haral or paar www wfl b» Mpaditad wbaa iaforawtii i> rwpMtod. Afl rafacala for data or arfar—tiaa w«B be raapoaded to i
EPA aad DOD win aobfy each other prior to prniidii Jfce «ber Afoacy's Mf aarim or dtta to aMfaer ^rty. A8 oaafid^ial baaa
agwacateat i» •abyect to piotcdapai act forth M 40 CFR fmt 2.
Tbi aocbca oppim to iafarwatiea nfead to afi nftame aahr webai 3 of tki* a
7. RESOLUTION OF INTERAOENCY CONFUCTS
i woriaeg: days of *b re^aa*.
Any rmflirt ariaiag aader thai a^mripnir wiS be raaobad at air i; law* i levale of Ataar/ dadaaoa atokaag «m3 apwaaaai: a raarbad The EPA Ragkaal Adoaaialniar aad the
OSe«r the Defeaee rm|inaiin M^ar Coaaaadis
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Where Sfvropn**- BP* K«*M*ai Offie«a and DOD Mkm aay mm ma agrztmcm «th »«e «ad bail Mtharitie. nmanfa^ imtmoin maiem. Sachttmamm mm he
cowato* wiftlto vm. e*eei* itac diipoe naoioioB waa ®f ,ariiiigi«»e«» WO" "'I""*'' •«a»oo ? of tfci» MOU.
9. amendments
TfcU frtxiBczKmy be raratnd m any an* by maaJ atraaaea of EPA mat POD. Ameadmem will be a wntmg, mi ofll be «gnai by appmaim DOD and EPAofikiab.
10. PERIOD OF AGREEMENT
UakH aM or umadail by musal mgnxmat. tfei MOU win cottnm, m effect ait December 1, 19S5 Tl» apmmm, my be toranMed ^ua aoa&axxi by cfefaer DOD
or EPA tt> tfee «d*r (any. A mrrainan of nay dayT advance wise* aabce of urmmoce a
11. EFFECTIVE DATE
Tto wffl bee<» eflectits upon ngntart of bofa partita.
//£'/ Uwaea 4. Iflrt
LAWRENCE I KOKB
Aaaas SaenMy of Detaie
IT lull 11 inn Raacr« Aflain ad L-agMa)
Dm: «D// M2®
IISII UM. TkoM
LEE M. THOMAS
Office of Sobd Wa*e aad Bn»»»ty Raapaac
Date: iron 8/12/X3
* Dikt*** For Rftfcnscc Oviy *
N-6-3
0
o o
fx/
9
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APPENDIX N-7
MEMORANDUM OF UNDERSTANDING
BETWEEN
THE AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY
AND
THE U.S. ENVIRONMENTAL PROTECTION AGENCY
1. PURPOSE
Tbe Afeocy for Toxic SMhaanree ud Disease Registry (ATSOR) sad the Esvtroaaettl Protection Ageocy (EPA) «pee tfca » leqarad to define nd
mud reapectrvt respoasiMibre infer tbe Cooqvefaeanve Enviroame^l Reaponi. Cumprnfirwi, ad tiebibty Act (Pvbbc Law 96-510. 94 SttL 2796. 42 USC 9601 et seq;
CERCLA). Execuve Onfc* 12316 (Rcepoaaes to Gbwobbm^ Daa*e). wl the Nmoml OA aad tfczzniov Coai^eocy Pfcm (NCP; 40 CFR Part 300). Tfau
MeaoodiB of Uudi irfaiirfing (MOU) rrtahiiabu policies aad prmodnrca far ludintag reapoase nd una rrspoaar hcakh activibca retaed to rclo—ri of bazanioui sobaaeacea.
2. AUTHORITY
TH * —— ,/w "u—:— '* r I'n nlami iweaheaaial tbraae nf nlaine iantfai naiiiiMiiitf nfbaiailma iri—in II and main rriliama nfpntl—m
or coMmxsaaa. CERCLA also eaatfshee the Hnrdtn Sabaaace Rn^in Trnrt Fnd. CERCLA secboa 104(i) rtkniw ATSOR (pot of the Dqitimi* of Heakh nd
Homo Services (HHS) to effiertaae nd aaplmea pacific heakh-nlatad acbvibae with the cooperation of EPA nd otter ageacies. Execathre Order 12316 tether to
tbe SocirtMy of HHS corns Hvastigacvy airtiaiboe vmd n the Pivsida* ndar CERCLA mcSmb 104 for nahi Hag actmbss with tbe mupwaiuu of other ageacaes. ' 1 ¦' g
to flbaa. disease or coophatfs thereof. Exeucive Order 12316 delepaea to EPA the priaary reapoase eahoriry ndar CERCLA eecboa 104 ralahag to reiaaae or nm of releaat
of haardoaa sobaaacee. potbna*s. or caaaaiaatae. nd detenaaain of the fu—ui of n immmm*. nd safaeaaial daager to the p^fcc heakh or welfare of the eavirmea.
Eicepboaa to tbia eahurity adade reeponee to releam from Departae* of Difn (DOD) fadktna or veseels (delegae to DOD) nd nkaMi involving the ooaaal zone. Great
Lain waen. ports, nd harbor* (deleted to the U.S. Coaet Gaerd).
3. SCOPE OF RESPONSIBILITIES
This MOU cww the coonbatfiaa of baakh-rahfted aebvibaa by ATSOR nd EPA m by CERCLA nd defaced by Older 12316. ATSOR has ntaory
rrepoariMibe* nder CERCLA aad Ewaiw Older 12316 far arthribes related to Staees, disease, or conpiaiaa thereof, for disease togietrioa nd
to reepease action. EPA hes aaatory aoAcrity nder CERCLA nd Esecaiv* Older 12316 for aebvibae rabfted to rrlnair or threa of releaee of baiaiduwa s
*1 for (toiwiiaioi of the eaart oi tegcr to pafabc heakh. uttw or the avnaaaa, as w«fl as, other reepeaaUibas raided to i
ATSOR aad EPA wiQ awry o« their na|iiniMitiiii aoooriag to CERCLA. Eiiaive Older 12316. tfa NCP. ^ 4a MOU. ATSOR'a «jar tuyinflgly wffl betfaa
of popaisboas with canra or pota^iai cijj ueai ii to ma^e aitas. irvdopmm. ATSOR'a ovataabaas of c
effects nd wiS ad^t EPA'a risk aseeeanetta « a ata or afees. ATSOR wffl aot peifma risk a
*itihafrui in Reapeaaa Traat Fnd. [f riak aeeaan an aot enviable ATSOR oeadact Mac of its a
of the Pobbc Heakh Service tfeoagb eoeperattva afro
iachrie those with the Cmm for Oieeaae Corral to coadact heakh —dies aad coadart raa^rhnd prwide mmrn^t oa wartor haakh nd m£*y isaaas; wkh the Lftrsry of
Medictae to eatabttsb aad aaatfaiB the aeeded d— baaos oa ha^kh cfEada of toac sahataaccs; aad with the Nnonl Toxicology Pr 'gmTT to c
Defiaitioaa for the 1ay tarm ased m this sedan faflow:
. Health Ccnnkaiaa laasediMe or ahat fcjra coaaahatica by ATSOR to piwide haakh advice nd/or haakh effects infia lanim ' t 1 r g a tpecific aite.
- Heakh Aiacata: laabal aaki-diecipfaagy it-vieaa by ATSOR of all readDy available dafc to ovah^e the atn aad aMgaaade of aay threat to bnaa baakh a
Tbeseevluatioas will a^pt EPA'a riak aaaeaene^ far thacteaattari—in of pota^ial haakh threattal a aite or abea, aad way ¦dadebanTeaaarchaa.iafbi
aad evahMin of eaatiag earin^acMd 4ft. pAat aanpies. taflav ^ food c
- PaUic Heakh Advacay: Aaadvieory ieaaed by ATSOR bead oa the nsaks of in I
• Epideaiokfic Stodiee: Liwg laiui apadmi njngii- atady by ATSORwrohiagaooMprahaariTeprotoooideBagndtoaddhaiiaiiilgii ofthahaakhoffecttofaapecifica
i A a aite or ad»a.
i Registry: A sde-epecific or adve—e haakh eflscto-epecific lagiatty <
i to tosic a
•POotSariy: a prchsMry or ahort tern ¦edinai. babamory, or apidawdagic atady oaatniled I
Tbe atady pop^aboaa caa iaciade thoae tmag aL or aaar, a ato aad thaaa aot nadiag *, or aaar. a afe
- RiskAaaaaanatf: A gmkmrf/grnmimrr* |ii man ooafrctodby EPA to c
of I
A. Reoowal Acboaa
Renoval acboaa are S^erfnd rsepoase actnicia javeiviag the ahut»
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B t<*»«tial l»fw
Rtnxdad actim an tfcoae rapmac aaiw cooumat wtti ¦ [mia reandy « « ate. Remedial •coao a preceded by 4conkd [daaaim Tii» acedga ;
-Pca.aitayitadyCFSi-.aad
- Roawial doiiga aad wa«riiel»aB.
The rcfos of ATSDR and EPA dwug these Mgea are diaaiMed is tte mbaecaoa* below.
B.l Site Dmamty. PnSammry AMausea. aad Site kapeetias
Tin 11 bit itifffrTrt mrfc-** f-H-iri*rh|r -V- fnr ptntpl i» iiikImI ii«i»i«i laitrrlhr 1^iiifiilT>mpwi CERCUk »ectxxi 103 roqara certam pert** to aerify tlx Naboai
Raapooie CcMWufcattey ka*e Inmiedte of a xdaaae of a kazanta* niauee equal to or a egaaa af the nynabk qtaaaiey tor lit witamax. NaifiealioB • faraardedto
E5> A and the affctmd Sbbc taaiiliOBioaia foraal oooSacxxi procaea. EPA aqr ream acti&ataoa of a pxeaiai or actaal nfaaae tnaa a local. Shte. or Fodeial t^sscy thid
dacoranteialiaii ia1te|ierf«—aLoofila reaptilaliMiii. Fattowag pahfiabco of a | nlirtal or aefl niimr. ¦ EPA coadaca a |»i Kiiiiiai; awwuin* of tbs me. to toiria
I ani Hazard Radaag S)«nn (HRS) acorav a i
Sao dtactwat;, paiaaiaary ataaaMK. aad ate ianmi'iiwi are |«inaiij' As inyu—TaWy of SPA. If ATSOR iaeaasri a pnwrtil or adtaai relaaaa dariof the imfaaaa» of
*J napoonUatn. ATSDR artfy EPA of tiai rebate EPA aay perioral [iiiliiain} aaaeansa* ™d ate tem.Tim of nek riliaaw. as »iuiaa»iil. aad will detenaoe
B.2 Site Knfcagnad NPL L«|
CERCLA Mxiiai 105(8) ra^aipai the PraidHt to dwatap cntni fee dMrBBni nwikiM aaMay rtfamaa or tivaalamd niflMi of hasntiaai i
criteria, patiah aad ¦irari fV NPL. SnmiwOdar 12316. Kin 1(c) deiegaas to EPA *11} ha reapoaMity for.. .all of the ... fiKwai vested iasoctiaa 105" of CERCLA
Dec»o« r^ardiai n*cific ale xxjnat wd 1««»| of ao» aod» NPLaro the r«po«aa«y of EPA. ATSDR my Ma—iaa afac^paealail taadidwea far At NPL
itniij Iti |iii fn —a II ifn i H|iifHMiiai ATSDR wffl aoiM tjaa irforaaboa to EPA To hcHtm das. SPA Hsadyatmn aaifr ATSDR piiaf to larfc —natural of
dae NPL lo aflow ATSDR to imnal ana to ha cniidi—d. far Ika NPL, aad SPA w« ccaadar —A 11" laaiUMlWiiiai. baaad ^na tka dM aaad hjr ATSDR to Bate to
. More paUiaiiai the aaaadad NPL. EPA Bay darida to laaic liaa M—ifiail ky ATSOR. Mia aa§ iafm—«i ai oa SPA Sim for team iiifiwu. or aaak
¦ aba* tacfc mm. and wiB acaify ATSOR af ib dafiwoa.
B.3 Rf idiil la imipaim
CERCLA (aclnalM RigiiiMl Admmttrmar, cr km dtmfme. cooler tto fofienwaf «nfeor«:
¦ RI/FS i
pOfoMkn iKoic «o tjyowd. after coMadonoc EPA'* rMt
oapocadjr tf soeii potf
iililifi
of am* or Mara M* cff*eo to m
bf ATSDR Mf, or b* SMe.
if time cnfiMM are sec. tfe BPA Rii|iimT
hf Irti i^sot imo tin RI/FS. Akuutuwiiy. ti»
Hrmrfi of tito inunlii in i m^mck ATSDRiitei —yarfortn reriowofatp t
wortor bodft «d wfiecy, c«ttaa«iiKy rMom, ifa mom4U iwi Kij^iw raport. Tka ahiMa of mini—"liflMna md i niii'ii—ina Utwout EPA md ATSDR m oadoctMf
tbeae acMiioa is dMoaribed in to fiflimi fanfnpka. EPA aorf ATSDR «3 OfTM to *net tisa aeMMat at s ate»-«pacifie taaia lor al meihiAm to bo jnwfuiad by ATSOR,
to i aawrr t^i the f. BPA wffl bo wpcaaftla gortbaioiiafc
nri tk» tcati titanfor. ATSDR voB
t*. If Ihmb aribjact tailim ia AriOTHMdi to ba wtommry, ATSDR ba napoaaMa
E to a—to ooflyboa of 1km ¦¦M to BPA aa parfarviat MiMMpoat mk
Saapiat Pnstocci. Vbare EPA baa nuyo>ul ^uacanaatATSDR ian nh laaai, BPA aarf ATSDR o>B wfcwrit »4wRof aipotooalno aoc>ator faritiww prior to ¦maaki
of aay —e —^wy or poaitona|. Aag cbaagoi aitia aaayiai |HuUiLuli oiB ai»o bo ytvi j
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Dtt Aaalyai* and laerpreM««. AT ansa where EPA ha* requested eqmmtt ATSDR iavoivemcat. EPA will provide k* data itvm eaviroameaal. toracoiogieal aad giber
i*oio£K*J wmpiing Bad teMag to ATSDR. ATSDR wffi review all available data for a aa*. iuduilijig EPA'a luuml ideai6ctt»oa. doee-reepanec saaesamrrt exposure ¦¦wiBgl
aad tiik dasscunMioo wfotwmxn. *awsig coaicha«w (box any ttaats to politic baakh aaeociaaed with the site. Based on at iaerpntatioa of the ear dam. ATSDR will
chanctcsixe the beakh Araais based ee its e«*ln«iQa of emm, beakh effects aad m coas^dion with EPA cooctsnaf the m*&made aad tiamg of pnarmal fotare health effects.
ATSDR will sJotnmmcBe all heath concern to regional EPA staff aad will provide copaea of haakh anfaaniLim aad adviaonee to EPA.
Worker Health and Safety. EPA nay repeat aaaiatsiy* front ATSDR oa «vtn batt aad mSay issaea J*y aady qaidaaci. For 4mm mmi w^kcb ten h®i Ihmsb ATSDR AivofctiBiMt*
EPA MKff wiO to—yfc ATSDR for itt ¦¦¦¦—c* of my kmmm hMtt 4m (•*.»ettoi, efidemoippe) aad SPA'* nil: unmm ii miiim 6nm the iwedhl ir'iwh|tiwi
EPA wlD be i ni|ir—¦Me far |infiwim inwliMfi'i i/¦§ twiu ri»k» to pdilii tkat ary raadlfrcm eepewpeto hwiikww n^iwnrm Iron
Saptrfmi MEM.
It»Ifae raqpo—ibflgy of EPA friTii (i f lnliit Ti'—in "lit Hmiiiiw j In ¦¦ iHjpinTii iw iiiMi nf Ihn ifal pin mt mm] nf lmt% mi—in n EPA ffnpfl Oinad EPA HMrlrpMrtrn of Hm
Far etek rewdki rapwii «to i*er» ATSDR pfd^-cwM Is rtqmMod. BPA wfl pro»idk> ATSDR Mi a copy of tb» dnft CnaAfiity Mdy, m! i4wi ¦mwiyiMB vidi rooffa
ili.H iMi ¦¦ nflli fi—ilililj liilj nhlii In hiMMii ImbIIi ¦¦¦! iMujiiiMiiiii. jric imhinwMii 11—ill j[iiwii»l if[ii—lli ATSDRwilliwowAeaBMprMMioB oftbotaBMB
famtt a tbe db«A fwwlilry «ady vd jrovidc MwmwMi to EPA darflif the p«bbc coohmM period. ATSDR will aito pwiift to EPA *Kf kakii BrfmaaUni * ppMinMri
oetfae site 4miag tbo pafabc ocoMKMpenod.
B.5 Ri Hiiiilial PMiga taal Cubmumhiuu
'firrTiiti rrgrirr -rnwin rlriinitf nfttir rm rittiHrngn Atlhf ro«rtMi*MoftiMdMW^
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6 EFFECTIVE DATE
Tfau n ii i ' ' In ihn nfiln »i miaul trl
Hit! OomH R. Ctlkgible)
Db: May 2S 198S
Far Agmey for Tonic IfohMirm mi Hmhs Regaiy
//$// Jack W. MeOnw
Dtfc: 1/0/1 4-2S-IS
Far Ac Vmti SMm Eii.iwmu—1 Prntectioo Ageacy
Cjpwd For tafcc
H-7-4
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appendix ns
MEMORANDUM OF UNDERSTANDING
BETWEEN
THE ENVIRONMENTAL PROTECTION AGENCY
AND
THE DEPARTMENT OF THE INTERIOR
PRELIMINARY NATURAL RESOURCE SURVEYS
1. PURPOSE
The PcyrtofM of the laterier (POD and! the 5n.ii nam ml Pntecbm Agaacy (EPA) agree tfe*. thi> pomaauUm of \mh% Hauling a im n —p la tapport fcdoml enforcement
actioae pml to the ComprehMRve Eavinmmlal Reepcoee. rnnfiiiiaariiai aad UaWity Ad of 1980, a* — wndnd (CERCLA), 42 USC Secaan 9601. et eoq. . DOI w& aeei*
the Uadad 9mm is tnefciag ctxsprefeeaifve mkawna of aD Fedml dni wfcr CERCLA by tnhi Ha& marrcyt m iasardoas wmtt sites of atfval feeooreca for m*»ch DOI
acts a* tnatoe.
2. AUTHORITY
CERCLA Steam 104(b) aad Ewrtzve Older 125®. Socm 2(f). aohorizad EPA to <»nfim ifntafifgina of icfcatts ortknB of rrinasm of lauankn idinirn no the
eowanA nd cter m:caaary mforoMboa picng to nfaroe the nwiwci of CERCLA.
CERCLA Soe&oa 10?(CK2XA) atfhorisee £e P*eride* to desaprte Tmknl cfScmb to act as aatatml geaoarcc trstew oo bafaatf of the pebbc. E»adi*» Order 12410. Sactka
1(6X4). nd the Nrtknd Ofl ad Hamilton Mmmw Poflnae rra*iatii»~.r Pin m to partieipaie ia. aagotin<¦* of eatiaanMs at Mies v4we there ii the
pntftriai far daaaagta to Kami mwnw. EPA agree* to npfeaaqt thsee cocnfinboa prmnm with DOI, Tie ptm iffl addraas the coordnain proririon idbacqaeat to
the MfiauK of this agreeaaaat.
4. SCOPE
Uadortheattfearity of Section 106.107. and 122 of CERCIA, the Uaiad 9mm way adridy par—e tie aattfaaaaal of daan agaa* person wapanftb far rriin m of fcaaardon
sataaaacee mo the enwoaaaetfL 2tach eeslenaat avy aKiade ooweami act to en rapnsMe parties nder vbwCLA with raspact to dsn lateaso of a hannkn nbafcaoe that
it the eabjcct af the etdcaacai The Uaiaed 3aao> ay provide a covqant aot to an fordhnagmto aaflarii rmomrom if the Federal tr—iw of the affected raaaarcm fi»ea wnan
| ri'—cef nni ii na|iiiailli fn< ilKiuaiwag ¦!¦ac for the unfun.maai action. Won of the fnd« piuiidiJ nder agftnea tkmH bt nod to fkm or ooadm Mtt—I inowroo danage nwaa—afc or
S. PRIORITIES
fTTVt -f'mr- Pi fiiif ITiifrr-iiiii^ r'TT-iH Hmtifrtn r^T'i Tffin -ff!irrr ml TVtjt-i Ttinr- rfTlT) m rmffm ynUi eaj itra nln wna*ximi
for qrforreanr of twbjmJt to ngoaawii. vMurjiaaid of oagoiag, iiimimnfb^aapBioaaail nsaoarcca nder DOI'* tnaOMakp. EPA't Regional Project Ofioora
(RPOe) wffl wrkwth thea^swpnate DOi Ragtoaai Biwroaneml OfScaw {RiBCN)to dteoane Klicfc haaapden a umaaMi;, niew aad niwancy ariwand ri^r
pvty aeda ae mob m famHm. EPA'a aJti&aikm «i aae a wmxmmm anoaal of rntamn Hat «iD be aflgwad for each ¦ >»/ iaciaded ia the work pin. The
EPA RPO mSL tfcMhie artifirahoa iwttn <30^ da;* of lauuiiiaj tha wwt fdi QEPR May prryoec ¦ rernad «wct phw c« the of the RFC appiiiial mafeanwaa—- DOI
wU1 be anted to Ttmbmmemtm froaj EPA beyond the aauhataa pacified ia the approved woric fdaa> if n aaMa^Bcat to the worlc pin a agfaad ^poau ai wnbng( bf tha EPA
RPOaad OWPE.
N-S-l
0 2 2 7
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7. SCHEDULE
OEPR will aonaafly ajtaptae a preisdaery nBni raoora mvey Mta tuzy (60) day« of ifac KteUnl itaniag edtde coax be
met, OEPR w01 o«ify tte EPA RPO, is wniiag. of tic «i of dehy «=i the wBneiied addit»c«*i lias aecawy for caatptebea. OBV^xUctaKtik EPA RPO it ieait
fifteen (IS) day* before the cad of-tir ml «J-d«y period if —i time i» ttxemBy. By motml agm«m«. SPA may nfM, aad DOI a*y omrtnrt • piMmum/atrvty
ca «a expedited ectedide.
8, SURVEY PROCEDURES
OEPR *41 eoaduct preload Maaliwaarcetarveyiaccoidiv to in mm proa*** aad tfae approval varieties- OWPEwaiUeattfy £>¦>•» R*0» *A» «B. apoa reqaeac.
provide DOTi REO» writ «ete«a«t tetfeakal dooaaoia. dntft aad fiaal aadtmwaad aaii'aauii i*i, nnnttl amnannw aad feudality acadiea (JU/FS) cad reaadU Mfat.
comwg iD prqje^ «eg—i. ¦wbnthrr prepoaed by EPA or fay reeyo—flik partiee. Siaveya will be locally directed, afaamrfeaabk. by DOI'i RE05, OEPRaayaieo coordiaaae
vnb attar nw m pctiammry wnyi wkea epprapnau
9. reports and documentation of COVENANTS not to sue
Withm thirty (30) of i Mptoina of oacb [reHiaimij —al reaoto «*ay. OEPR atoll rabmt Is tba EPA Ml to OWPEa wuiim J report dat inckitu a detiimitatim
if ll» |in«ia«ial tor dHM|oe*> Mail mooreae aader DOimaeoMp, tke baaie far Urn. i »whainn. —d a ckar i«lia» arfn ¦rfiia to the ejgqa fnniWi had m iafn'iiadiw a»aiaMe at the fae of frc wrrty. OEPR
y to eaabte DOI to reepoad to OWPE.
satyr
lafmHim ca DOl'i
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w*i ttapeaaMe pwaa
¦afeeabaBnaaiseaafidaaiiil. DO) wffl ataattiia So of firiap of fact iac-r, ,
t of dafifawttve prooeoi. ^¦Mwy^lMAt aid knmL ivodact. DOi or DOI May rapraeeaK DOI'ft poMsoa ia angotiatioaB
DOI amy afree to a i
ofapropoaed re
dto
ipi# tto Mft fir vtam! i
to t OPMNMt aol tO I
ait impaled. EPA «B caanll DOI I
of Ik* propoeed raaedial aam or Ramd of
*» EPA a»» irt—ifirrtna —limn aad m* tmm. Where ¦odiSa*»cer
of nek Mm. OWP6 aad OEPR wiB earn ae tbc iimii for iaeaee
aotto
... at. SOC'i apt nepwa «th the fraw of MategeB or atwmaitl to
wB be ceewyedby l«e«r framtfcc SeBeifor of *» D«^it*«of *c leeierlolhe Awieal Aeeeqr Oeaoal far Noial SaaoBtn of An DepatoacM of Jaain.
10. REIMBURSEMEKT
Sarw? cant win laiiiaibM mil oaaam ip»ci£c taM»*»aa^>a«hMr>AfeyAtw—flAO). TkeaflotMio— »iB WbaxdoaOBPR'xBirawd wo»fcpfcai«adcqa laiiifiii.
aad K^l Mm m OEHt't M(et for t» i
mfcidb mr* i iiw>jiwMii by the Paad:
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Ui tjr ShmW
e) DOi
DOI EPA.
Raabwwacat««n b® ande wittn farty-fire (45) <%t iter ¦ —rmy i> oaapimi mi EPA RJPO hw wcamrf Aa npat nfarvdtD in 9 of Itm <|hu,iimK. EPA
mmy allow • foflow ^ tmrny mAcr 1m ¦finfuri for thoM mm where tk> of tin miM fnimamry mtvmy mm mndSamtt far DOI to dmrmmm nMw to «p«e to
¦ i in iimim m in in it Mini m ¦¦ fj mnwhT tj!¦¦ ¦flj iiriT llw itiaiifai DiwiTImiiiiIbiI liliiw ftDTHI ¦¦! i— hiilii i mi nftlrn TTTi TbsaMtt
for tbe kflow^ wmmj wmM be mcrtmemi to tkmm mmd ani nd M b» fcy BPA RPO pnor to ¦>
11. ACCQUNTmO REQUIREMENTS
EPA. actieg w of dw Heordbe 5
wSkBi, DO J wffi wbnit to EPA m TWfao* far f
b o> CERCLA nmpam
late Lao. SiAii^MwdliKUBi
1 ihi i iihiiiil iiMiflinii ofCERCLAfMi £ortka»e
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DOI ai mqiaiid to kaep 4aanied 1
cf 41 ootfi iKmdL Una acooHto aliorid aKtele, mn aot SoMtad ttK mmtfkgfma Vnn 4paM^ racaipti lor osaiflriaii,
^ ^ , aadi ooMnoktiaa. AS^oosMtlHAlMnaiMiiaMlanafliMpMificlBMi. DiM2addkMMaMiHMnwOWPE»ai«midaDOIaet»oeof. ¦¦doyyortaai^iopailiLMUM. ¦¦giliaiiiai watr—peaaHa
• fori
. EPA vd DOI
13. POUOD OF AOKEEMBKT
Th.
1 <*afl a^ly to aB i
of ho& parbn or KnaaMad by «dw ^poa a 3CMay %
fros iu effcoivt date or wbeaevtr CERCLA nay ba fadfaer aaraded
k Ad nam ia effect
s adl he ranoavd by As £MOce awiy yean
H-8-2
02
2
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im negate
I. Wanton Porter
Ammo*. AdmniMxr for Said Vim «nd Earafeacy RnpoaK
E»iiiu«»iiii«»l Piommb Ataxy
1/0/1 \V6!tl
IIS/I Joacyh W, GarreO
Jotyb W. GccreU
Pm*Tj»l Depaty AmB Sccnwy Pofccy ami AdmiatMioB
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mil ivvn
IM One Luca-o
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Pi—Office of *«¦» f»P«a» Eafmxmctt
Miinal Pr«o=boo Agcacy
(No Dae)
//S// Bran Btactani
Bruue Btaactattd
Oir»c*or. Office of Prqjert Review
D< penmen of *e IMtnae
(No D«e)
• Da.it Cafi«4 F«r Rafcraea (My
N-&-3
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APPENDIX N-ll
M1MORANDUM OF AGREEMENT
BETWEEN THE
TENNESSEE VALLEY AUTHORITY
AND THE
U.S. ENVIRONMENTAL PROTECTION AGENCY
THIS MEMORANDUM OF AGREEMENT (MOA) is entered into between the Tennessee Valley Authority (TVA) under authority of the
Tennessee VtUey Authority Act of 1933, 16 U.S.C. SS >31-831dd (1982 iSupp. V 1987), and the United States Environmental Protection
Agency (EPA) in accordance with the obligations and authority delegated to it under various Federal pollution control laws.
WITNESSETH:
WHEREAS the combined expertise and efforts of TV A and EPA will assist in achieving their joint goals at a lower overall cost to
the United States and tile public than if work were performed separately or through contracts with private organizations; and
WHEREAS TV A and EPA wish to extend the termination date of this MOA from December 14, 1989 to December 14, 1994, and
to make other minor changes; and
WHEREAS TV A and EPA wish to incorporate the extended term and minor changea into the MOA and to teexecuteit in its entirety
thereby reaffirming their commitment to the goals and provisions of the MOA;
NOW, THEREFORE, the parties agrae as follows:
lit PURPOSE AND SCOPE
1,1 Purpose litis MOA sets forth the base principles and guidelines under which the panic* intend to cooperate in environmental program
areas including research, development, and demonstration projects; the exchange of ideas, information, and data; the utilization of laboratories,
equipment, and research facilities; emergency praparadnesa; compliance repotting; environmental auditing; training and education; and other
efforts to further the advancement of knowledge in the general area of environmental policy, regulation, compliance, research, development,
and demonstration. The MOA establishes; (1) the method for development, incorporation, and administration of various subagnemenss; (2)
reporting requirements; (3) mechanisms for fond transfer and accountability; (4) procedures for publication and release of information; (S)
procedures for modifying or terminating this MOA and/or any subagreementt issued hereunder; and (6) procedures for determining rights to
inventions made in the course of, or under, the research, development, or demonstration work effected through this MOA.
1-2 Scone: This MOA deals with environmental programs and does not involve other activities of EPA or TVA. The specific nature and details
of work hereunder will be defined and provided for in subsgreemesu executed in accordance with the provisions of this MOA.
l.ft gmARBKEMENTS
2.1 Defiaitioa: The subagreemeota issued under this MOA will be jointly developed by TVA and EPA. The subagraemeots will identify the
lead party, the project objective(s), approach, uaeoftbe other party's facilities or personnel, eost(s) to each party, milestones^), approximate
duration, rxponiibiliti— of the putwt, ippropnitt pttrot provision! t nad tirniiir detailed mfornmioQ for tidi effort or set of efforts undertaken.
2 J Approval: Approval of subagrsetnsots requires the mutual agreement of TVA and EPA and is subject to the availability ~f funds. For
TVA, d»e Pngect Manager or Program Coordinator will negotiate the terms of individual subagraemiiMi and obtain TVA approvals therefor in
accordance witb existing TVA policy and procedure. For EPA, the appropriate EPA official will negotiate the terms of individual subagreemenu
(including funding), and obtain EPA approvals for diem in accordance with existing EPA policy and procedure. Subagreemenu ao approved
shall be subject to die tanas and conditions of this MOA.
2 J Justification: In subagiueiueuu involving disbursement of funds, a strong justification must be included in the deciekm memorandum to
EPA's decisionmaking personnel which explains why the project is being included through this medtaniam and not a coatraet or cooperative
agreement. One or more of the following items should be explained in the justification: (1) the unique capability of the other party that places
it in a preeminent position; (2) the confidential nature of 0m wotk precludea use of other sources; (3) the continuation of a previous effort
performed by the otter patty that cannot be continued by other sources; (4) the other party has personnel who are considered the foremost axperta
in fields necessary to perform the work; (5) the other party has facilities, equipment, or data which are specialized or vital to the effort and which
no one else can provide; or (6) a situation exiats where no other source provides the goods or services in die time allowed.
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0 2 3 9
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3,0 ADMINISTRATION
3.1 TV A-EPA Aiimirr^tT-gtioa Groom: To implement this cooperative agreement at policy miking, program coordination, and project operation
leveli, the following will be established by the patties " appropriate: (a) An Interagency Coordination Committee, (b) Project Managers, (c)
Program Coordinate™, and (d) Agency Coordinator!.
3.1.1 Interagency Coordination Committee: An Interagency Coordination Committee will be established to provide executive-level interaction
and to function ai a management board or informal board of directors in considering fiscal matters and program planning under this MO A.
This committee will be jointly chaired by the Agency Coordinators and will meet annually. Membership on the committee will be composed
of representatives from mutual interest areas from each patty. The committee will have the authority to establish and direct subcommittees and
working groups to conduct specific activities necessary to carry out the following committee functions:
(1) Provide a coordination mechanism for exchanging appropriate budgets and programs and multiyear plans of the two patties;
(2) Provide effective ways for technology transfer and exchange of data, information, and program results of mutual interest; and
(3) Arrange for cooperation and support is the conduct of-programs of mutual responsibility and interest.
3.1.2 Project Myiyf Project Managers will be designated for all individual projects undertaken pursuant to this MOA. The Project
Managers will be responsible for the technical and managerial oversight of the projects.
3.13 Program Coordinators: Program Coordinators may be established to develop, coordinate, and oversee projects to be undertaken in
program anas of mutual interest such as land, air, water, or waste. The Program Coordinator either shall oversee the activities of Project
Managers who are responsible for projects in selected program areas or shall act as and be the Project Manager.
3.1.4 Agency Coordinators: Each party shall have an Agency Coordinator to provide the day-today coordination and liaison between the paitiea
during the implementation and performance of this MOA and to oversee the activitiea of their ageoctea* respective Project Managers and Program
Coordinators. For TVA, the Manager of the Environmental Quality Staff dull be the Agency Coordinator for all activities under flu* MOA.
For EPA. the Director of the Office of Federal Activities Aall be responsible for administration of this MOA and the Regtooal Administrator
for the EPA Region in which activities under this MOA are proposed shall be the Agency Coordinator and shall be responsible for implementing
MOA activities in the region.
The Agency Coordinators shall have the following authority and reaponaibUitiaa:
(1) To aerve as the principal and official points of communication between the two parties relating to management and/or policy
matter* for this MOA;
(2) To ensure that subagreements prepared for approval are in accordance with the terms and conditions of this MOA;
(3) Respecting each EPA Region, to ensure that a complete inventory list of all subagreements entered into under this MOA is
accurately and currently maintained. The list should include the duration, funds transferred, contingent obligations, if any, reports,
and other relevant information for each subagreemanfc aad
(4) To assist in the resolution of any diaputethat may arise in the implementation of this MOA or any aubagieemant.
3 J Program Planning and BadMt Coot itiiialion: Each patty desires to keep the other informed of its annual program and fiacal planning,
so that the environmental activitiea of both including reeeerch, developmart, and dsmoortatioo in areas of mutual interest are coordinated in
such a manner as to be complementary and to avoid unnaceasary and counterproductive duplication of expenditurea in terms of monetary,
physical, and manpower resources. While snefc patty is responsible for its own annual budget and program planning, (he parties will consult
with each other and exchange information to the extent appropriate, including preliminary drafts of budgets sod program planning documents,
so that each patty will know what the other is planning and budgeting for in areas of munis! interest.
33 Stalsusiian of Ptm—wi: TVA and EPA agree diat it may be mutually beneficial in achieving the objectives of this MOA for personnel
of one patty to be stationed at faalkiss of the other patty for a period of time.'
Stationed employees shall not be considered to be employees, agents, or r«|iiesiimiives of the host party, but shall remain for all purposes
employees of their regular employers, which shall continue to be reeponsible for the employeea' salary, benefits, and other compensation,
including any relocation or per diem costs, in accordance with their employer's established policies and procedures. Employees stationed, and
security regulations of the host patty.
N-U-2
02 31
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3.4 liahtKtv
A. TV A Facilities:
<1) In the event EPA, hi employe**, agent*, or contractors utilize TV A facilities or equipment in the performance of work covered
by a uibagreemem issued under this MOA. EPA will notify TVA's Program or Project Manager for the particular subagreemeat is
advance of each visit to the TV A facility and will furnish TV A a lilt of all personnel who personnel will be envolved in the work.
(2) The installation of any equipment by EPA on TV A premises is at the sole risk of EPA, and TV A makes no representation as
to the condition or suitability of its facilities for the purpose(s) intended by EPA.
(3) As between TV A and EPA, EPA assumes full responsibility for any and all liability and claims arising out of or in any way
connected with the presence of ita employees or agents on TV A facilitiea or with (he actions or nonaction* of its agents and employees
under this MOA and any subagreement.
(4) EPA agrees that its employees, contractor!, or agents will conform to all applicable TV A hazard control and safety regulations
at TV A facilities-
(5) TV A assumes no liability to EPA, its agents, employees, or contractors, or any third person for any damages to, or theft of,
property or for personal injuries, including death, which might arise out of or in any way be connected with any activity undertaken
through this MOA or any related subagreemsnt. It is expressly understood that EPA shall have no responsibility or liability for claims
arising out of die sole negligence of TVA, or TVA's employees, contractors, or ageats.
(6) Tlte Federal Tort Claims Act (FTCA) is the exclusive remedy for tort claims against EPA and its eoployeea. Under die FTCA,
EPA is not responsible for the negligence of its independent contractors. EPA agrees that its contractors who perform work under
die terms of this MOA or any related subagreemeots shall carry adequate liability insurance.
B. EPA Facilities:
(1) to the event TVA utilizes EPA frcilities or equipment in the performance of work covered by a sufasgreement issued under this
MOA, TVA will notify EPA's Program or Project Manager for the particular subagreetnaot io advance of each visit to the EPA
ftcilitiee and will famish EPA a list of ail pereonnai who will be involved in the work.
(2) The installation of any equipment by TVA on EPA facilities is at the sole risk of TVA, and EPA makes no representation es to
die condition or suitability of its premises for the purpoee(s) intended by TVA.
(3) As between EPA and TVA, TVA assumes full responsibility for any and all liability and claims arising out of or in any way
connected with the presence of its employees, contractors, or agents on EPA premises or with the actions or nonactions of its
employees, contractor*, or ageats under this MOA and any subagteenient.
(4) TVA agrees that its employeee, contractors, or agents will conform to all applicable EPA hazard control and safety regulations
at EPA fteUitiee,
(5) EPA assumes no liability to TVA, its agents, employees, or comracton, or any third person for any damages to, or theft of,
propetty or for personal injuries, including death, which might arise out of or tn soy way be connected with any activity undertaken
through this MOA or any related aubagreemants. It is expressly understood that TVA shall have no responsibility or liability for
claims arising out of the sole negligence of EPA, or EPA's employees, contractors, or agents.
3.5 Third Persons: TVA and EPA expressly assent that by this MOA they nuke no promises to any other person; and nothing in this MOA
should be construed to five rise to a third-person claim in contract, tort, or otherwise. The perties expresaly assent (hat no third person is as
intended beneficiary of this MOA and the benefits, if any, of this MOA are merely incidental with respect to third petaooa.
4.0 DURATION AND CHANGES
4.1 Tens of Memorandum Anrnmejat: He term of this MOA shall expire on December 14, 1994, except as otherwise renewed, modified,
in accordance with the provisions herein. Paragraphs 3.4 and 3.5 will remain in force even whan the agreement is terminated
with respect to any activities conducted by the parties prior to lamination.
4.2 Modifications: This MOA and any subagreemem issued hereunder may be modified at any time by the mutual written agreement of TVA
and EPA, obtained in accordance with paragraphs 22. and 3.1.4.
N-ll-3
0202
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4J Termination: This MOA, or iny subsgreemem issued hereunder, may be terminated by ninety (90) days* written notice. at sny time, by
either ptrty with or without cause; provided, however, that such notice and termination shall not relieve the party funding any wort under any
such tubagreement from its obligations to reimburse die other parry for costs or expenditures incurred by the DOMerminating patty in accordance
with an applicable subagraement prior to receipt of the termination notice. In the event of termination, the parties shall take reasonable steps
to preserve the work or results of say ongoing
S.l Milestone Reports: Milestone reports shall be prepared for those milestones for which such a report has been specified in the
subsgreetneni. The substance, format, and due date of this report shall be delineated in the subsgraemeot.
SJ E»*»l A final report shall be prepared for each subagraement (or for each distinct project within a subagraement where several
projects are activities included). A mutually suitable due date for final reports) shall be specified in each subagraement. The final report shall
contain ail useful information acquired in the performance of the work accomplished and shall present all significant results with conclusions
and recommendations derived therefrom.
6.1 In General: Subject only to the conditions and restrictions set forth below, either party may publish or release information about any MOA
activities. Appropriate credit shall be given to die role of each agency in such information and reports.
62 Confidential and Proprietary Information: In order (1) to prevent the disclosure of information requested to be kept confidential or
proprietary by third patties or the parties or prohibited from disclosure by Federal law and (2) to protect possible patent and invention rights
of the partes or third persons, potentially sensitive information shall be reviewed by Project or Program Managers who shall seek advice of their
respective legal counsels as appropriate. The initial receiver of potentially sensitive information shall notify in writing the other patty's Agency
Coordinator so that inadvertent disclosure will not be made by the other party or its agents. Each party dull use its beat efforts to secure and
prevent the release of confidential or proprietary information consistent with its policies and procedure* and Federal law; provided, however,
that each party may disclose such information to the other if necessary to conduct activities under this MOA or a subagreemeot. In no event
shall either party or their respective employee* or agents be liable to die other or any third patty for the disclosure of any such infonnatioo.
63 *lil—nnnurr Ccpiea of any publications prepared or contributed to by a party utilizing the results of rmsarcli under a subagraement
and all press releases prepared by a patty regarding this MOA or any subagraemaot will be forwarded to the other patty for review prior to
public release or presentation.
6.4 Rata to Dissent: In the event the pattie* fail to agrae as to the interpretation of research milts, either party may publish its data and
conclusions, after due notice and forwarding of advance copies as provided in paragraph 63 hereof. In such instances, the patty publishing such
differing viewpoints will duly credit the cooperation of die other party, .but will assume full responsibility for any statements on which there is
a difference of opinion.
7.1 Pavmaits Under Unleea otherwise provided in individual subagieemema, each party will fund its own projects. In the
event of joint funding of a projects), the amount and tuning of funding shall be as specified in the individual subagraemeou. Funding for
projects to be performed by one party at the expense of the other will be on a cost-reimbursable basis.
7 JZ Final Acct-™«™f In the event of jointly funded project(a), or projects) performed by one patty atthe expense of the other party, the
expending party shall famish the other such accounting information for funds expended as it routinely generates or requires of others. Upon
request, each patty shall furnish die other interim accounting information, aa it routinely generates or raquirae of others, for budget purposes.
Charges by the performing patty will be on the basis of actual direct and indirect cost.
8.1 E»wirp«im«»rtal »»«»; TVA and EPA will review each subagreemeot to determine how aity activity may affect the environment. Where
preparation of any environmental unpad statement or ssiessirwnt is mutually agraed to be nacusury, die lead party in accordance with its
procedures shall prepare any required document. Any coats to be borne by the nonleed party related to environmental renews under this
paragraph shall be deUaieted in each interagency agreement and shall be considered expenditure* for accounting purposes under provision 7.0
8J Patents: ft is recognized that TVA and EPA each have patent policies regarding the ownership of inventions, and the application of these
policies will depend on the nature of the cooperative effort being undertaken iaduding the source of funding and the relative importance of the
effort to die statutory obligations ofTVA and EPA. Accordingly, appropriate patent provision* will be included in eech specific subsgteemsia
in a manner which takes into consideration each party's responsibilities.
S.O DOCUMENTATION AND REPORTING REQUIREMENTS
6.0 PUBLICATION AND RELEASE OF INFORMATION
7.0 FUNDING AND ACCOUNTABILITY
MgENEPMWVtyQNS
N-1I-4
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83 Capital Equipment. Real Property, and Facilities: Each subagreemem ihall delineate where appropriate, the responsible p«ny. the
applicable procedures and policiej, aad the finaJ disposition for all capital equipment, teal property, and facilities required to b« purchased to
carry out tile interagency agreement.
8.4 Congresaoml laltrat: No member of or delegate to Coograsa or Resident Commiuioner, or any officer. etn>loyee, special Government
employee, or agent of TV A or EPA (hail be admitted to any share or part of this agreement or to any benefit that may «n»e therefrom unlet*
the agreement be mad* with a corporation for it* general benefit or a unit of Government contracting for the public'i general benefit, nor ihall
EPA offer or give, directly or indirectly, to any officer, employee, ipecial Government employee, or agency of TVA, any gift, gratuity, favor,
entertainment, loan, or any other thing of monetary value, except«j provided in IB C.F.R. 11300.735-12 or -34. Breach of this proviiion ihall
constitute a material breach of thii agreement.
8-5 Funding: Neither TVA nor EPA is in any way obligated to expend fund* in excess of those authorized or available and determined by
each in its sole judgment to be sufficient to finance any undertaking.
8.6 Technical Assistance TV A and EPA wiU provide advice and technical aasistance as requeaed by the other aa each determine* in its sole
judgment that it is in a position to provide. . "
8.7 Agency: Neither TVA oor EPA will be deemed the agent for the other for any putpose unless otherwise expnsaly agreed in writing.
8-8 Permits: Unless otherwise specified in the aubagieement, the lead party has responsibility for securing all applicable licenses, permits,
or approvals.
IN WITNESS WHEREOF, the parties have hereto subscribed their names as of the day and year written below.
U.S. ENVIRONMENTAL PROTECTION AGENCY TENNESSEE VALLEY AUTHORITY
mi mi
William K. Reillv Marvin Runvon
Administrator Chairman
Dated: lan 19, 1990 Dated: Jan 9, 1990
N-lt-5
G 2 3
4
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ANNEX O:
PREDESIGNATED ON-SCENE COORDINATORS FOR
THE INLAND AREA
SCOPE: The following table lists those OSCs predesignated for response to oil
and hazardous substance releases in the USEPA Region IV inland area. Additions
and deletions to this list will be maintained in the USEPA Region IV Staff
Management Plan.
Tony Best
Mary Jo Bragan
Larry Brannen
Warren Dixon
Chuck Eger
Leo Francendese
Francis Garcia
James Hudson
Randy Jackson
Dora Ann Johnson
Bill Joyner
Chris Militscher
Matt Monsees
Tony Moore
Paul Peronard
Don Rigger
Bob Rosen
Gail Scogin
Art Smith
Steve Spurlin
Fred Stroud
Matt Taylor
Michael Taylor
Samantha Foster
i
0-1 (update JAN 1995)
0235
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ANNEX P, ESF #10, TO THE REGION IV REGIONAL CONTINGENCY PLAN
ESF #10 - HAZARDOUS MATERIALS
Primary Agency: ENVIRONMENTAL PROTECTION AGENCY
Support Agencies: United States Coast Guard
Department of Agriculture
Department of Commerce - NOAA
Department of Defense
Department of Energy
Department of Health & Human Services
Department of the Interior
Department of Justice
Department of Labor - OSHA
Department of State
Department of Transportation
Federal Emergency Management Agency
General Services Administration
Nuclear Regulatory Commission
PURPOSE:
When an emergency or disaster event triggers the activation of Hie Federal
Response Plan (FRP) and this Emergency Support Function (ESF # 10), this
Annex prescribes the mechanisms that:
• Coordinate the response by ESF #10 primary and support agencies to
supplement State/local response and recovery efforts to releases and
discharges of hazardous substances and oil posing threats to public health,
welfare and the environment.
• Integrate response operations under the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), the Region IV Regional Oil
and Hazardous Substances Pollution Contingency Plan (RCP) and
appropriate Area Contingency Plans (ACPs) into the response operations of
the FEMA Region IV Regional Response Plan (RRP).
• Define and coordinate EPA support to other ESFs
SCOPE:
The FRP facilitates the delivery of Federal response and recovery assistance to
States to assist in dealing with the consequences of a disaster. The RRP is the
•••Coordination Draft***
Revised July 18,1995
ESF-10-1
-------
regional supplement to the FRP and is used in conjunction with the FRP. Both
the RRP and the RCP focus on the regional procedures to supplement the
guidance, direction and procedures in the FRP and the NOP.
Neither the FRP or the RRP supplant existing plans or authorities that have been
developed for response to incidents under authorities other than the Stafford Act.
ESF #10 , for example, conducts field response operations under the provision of
the NCP and the RCP. Coordination activities carried out under this ESF do not
conflict with the duties and responsibilities of the components of the national
response system.
Through the provisions of this Annex, the Region IV Environmental Protection
Agency (EPA) and U.S. Coast Guard (USCG) responsibilities, organizations and
functions are established. These mechanisms interface and coordinate Federal
responses to releases of hazardous substances, pollutants or contaminants and
discharges of oil and describe EPA support to other ESFs as designated in the
FRP.
The procedures included in this Annex apply to the ESF #10 primary and support
agencies and provide direction and guidance to the EPA staff, the applicable
USCG Districts, the Regional Response Team (RRT) and On-Scene Coordinators
(OSCs).
ESF #10 POLICIES:
EPA Region IV, as the Primary Agency for ESF #10 in Federal Region IV,
provides the overall leadership for the planning and implementation of this ESF
and designates the Regional ESF #10 Chair.
All field response operations in Region IV to oil discharges and releases of
hazardous substances to include pollutants and contaminants will be carried out
under the direction of an On-Scene Coordinators) (OSC) as designated under the
NCP. Response operations will follow the policies, procedures, directives and
guidance developed to carry out the provisions of the NCP and will be consistent
with the NCP, the RCP and the applicable ACP. These plans are briefly described
below.
Responses by OSCs from the Department of Defense (DOD) and/or the
Department of Energy (DOE), as defined in the NCP, will be carried out following
appropriate lead agency procedures and in a manner consistent with the NCP.
"•"Coordination Draft***
Revised July 18, 1995 ESF-10-2
02
o n
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The National Oil and Hazardous Substances Pollution Contingency
Plan (NCP):
The NCP establishes the response powers and responsibilities created by the
Comprehensive Environmental Response, Compensation, and Liability Act, as
amended, (CERCLA) and the authorities created by section 311 of the Clean
Water Act (CWA) as amended by the Oil Pollution Act of 1990, (OPA-90). The
NCP provides the procedures and organizational structure for preparing for and
responding to discharges of oil and releases of hazardous substances, pollutants
and contaminants.
The Region IV Oil and Hazardous Substances Pollution Contingency
Plan (RCP):
The RCP is prepared in accordance with the NCP and with the cooperation of all
designated federal and state members of the Region IV Regional Response Team.
The RCP is applicable to all federal agencies who are members of Hie Region IV
Regional Response Team and provides for a coordinated, integrated response by
RRT member agencies and other organizations.
It is effective for all areas within Federal Region IV and applies to discharges of
oil into or upon the navigable waters of the United States and adjoining
shorelines, or which may affect natural resources belonging to or appertaining to,
or under the exclusive management authority of the United States. It also applies
to releases or threats of releases of hazardous substances, pollutants and
contaminants which may present imminent and substantial danger to public
health, welfare or the environment.
The RCP also contains a description of the jurisdictional boundaries of the Region
which define the Inland Zone and the Coastal Zone. These zones are established
by joint USCG/EPA agreement and are applicable to response operations under
ESF # 10.
Area Contingency Plans (ACPs):
ACPs are required under the provisions of the Oil Pollution Act of 1990. These
ACPs cover specified geographic areas within the region and have been developed
by Area Committees, which are planning and preparedness entities that include
federal, state, local and private sector representation from within the designated
Area. ACPs provide a detailed local response effort that is integrated and
compatible with state, Title III local emergency response plans and private sector
""••Coordination Draft***
Revised July 18,1995 ESF-10-3
I
02 3 8
-------
vessel and facility response plans. At present, ACPs are in effect in each of the
USCG Captain of the Port Zones in Region IV and are referenced in the RCP.
The RCP, with the addition of several specific annexes, serves as the ACP for the
Inland Zone of the region. Because of the much larger geographic area of coverage
of the RCP, the depth of detail is not as great as that of the coastal zone plans.
Federal Radiological Emergency Response Plan (FRERP):
Radionuclides are defined as hazardous substances by CERCLA. Response to
releases of these materials in ordinary situations is covered by the NCP.
However, any release of radionuclides large enough to require a response by
several agencies will likely require the activation of the FRERP. The FRERP
establishes an organized and integrated capability for timely, coordinated response
by Federal agencies to peacetime radiological incidents. The Federal department
or agency that owns, regulates or operates the nuclear material or facility is
designated as the Lead Federal Agency (LFA) for managing the onsite response to
an incident. Depending on the type of radiological emergency, the LFA may be
the Department of Defense, Department of Energy, the Nuclear Regulatory
Commission or EPA.
In a disaster situation, the FRP may also be activated. In these situations, The
FRERP addresses the radiological aspects of the incident and the FRP addresses
the non-radiological or consequence management aspects of the incident. The
Radiological Emergencies Incident Annex to the FRP describes the relationship
between the FRP and the FRERP. Further details pertaining to EPA's response
as a LFA can be found in Annex S to the this plan.
SITUATION:
A. Disaster Conditions: Federal Region IV is comprised of eight
southeastern states forming approximately 20 percent of the land base of the
Continental United States and 40 percent of the coastline. The region is at risk
from both natural and technological hazards. Within regional boundaries are two
major seismic risk areas, the New Madrid and Charleston faults. In addition,
coastal and adjacent inland areas are at risk from hurricanes and gale force winds
and tornado and flood threats exist throughout the region.
The occurrence of a major emergency/disaster in any one or more of the eight
states in Region IV could result in numerous situations in which oil, hazardous
substances, pollutants or contaminants are released into the environment. Fixed
facilities such as chemical plants, tank farms, terminals and storage facilities as
well as transportation corridors including highways, railroads, pipelines and
waterways are potential sources for discharges/releases.
•"•Coordination Draft***
Revised July 18,1995 ESF-10-4
0233
-------
B. Planning Assumptions: As a consequence of a disaster, multiple oil and
hazardous substances events of varying severity will occur. The demands of these
incidents will exceed local and state response capabilities. The FRP/RRP and ESF
#10 will be activated to execute assigned missions to supplement state and local
response efforts.
If sufficient warning time is available, activation of the REP and ESP #10 may
occur prior to the event and the declaration of a disaster.
When the capabilities of local response agencies are totally committed, local
emergency first responders in the areas most affected by the incident will be
unable to carry out a first response to all oil and hazardous substances incidents.
OSCs may respond to situations in the which local and/or state response is
minima] or non-existent. First response actions will concentrate on saving lives
and protecting property. Responses priorities and changes will be coordinated
with state and local governments. The ESF #10 Chair may change priorities and
allocation of resources based on available information affecting the whole disaster
area.
Assessment and response to discharges of oil in the coastal zone will be a U.S.
Coast Guard responsibility. Coordination of USCG activities with the overall
disaster response will be through the provisions of ESF #10.
Oil and hazardous substances facilities in the affected area will need to be
assessed and monitored by oil and hazardous substances response personnel.
Information maintained by State Emergency Response Commissions and Local
Emergency Planning Committees may be useful.
Joint federal, state and local efforts will be required to determine initial
damage/needs assessment information concerning the number, type and
magnitude of incidents.
Tioinq(to fn frsincunrfjafiah /*fiTPiTnnTti/|5ifiATic QTir? AfKor in f*rQctmr^iyog vrill nflrfiTWr
-------
ORGANIZATION and RESPONSIBILITIES
Organization: The Federal agencies that participate in FRP responses are
organized into a national-level support structure and a regional level operations
and support structure. At the national level, the organization of the Federal
agencies is the Emergency Support Team (EST) At the regional level, the similar
organization is the Regional Emergency Response Team (ERT). ESF # 10 is a
part of the ERT which is the basic organization for delivery of Federal response
and recovery assistance. Additional organizations and functions are established
by the FRP to facilitate the delivery of Federal assistance. A detailed description
of each organization and its functions is contained in Appendices to this Annex.
Responsibilities:
A. Primary Agency: The Environmental Protection Agency is the Federal
agency assigned primary responsibility for the management, preparedness,
response and coordination of the ESF #10 mission. EPA Region IV has
responsibility for ESF #10 operations in Federal Region IV. These responsibilities
include:
o Appointing the Regional ESF #10 Chair.
o Supporting the accomplishment of mission assignments with all available
regional expertise and resources.
B. The ESF #10 Chair: The Chief, Emergency Response and Removal Branch,
Waste Management Division, EPA Region IV is the designated ESF #10 Chair and
is responsible for:
o Representing EPA and ESF #10 on the Regional Interagency Steering
Committee.
o Preparing and maintaining the ESF #10 TAB to the Regional Response Plan
and the ESF #10 Annex to the Regional Contingency Plan.
o Ensuring that missions assigned to ESF #10 are carried out.
o Utilizing the response roles and operations designated in the National and
Regional Contingency Plans to respond to requests from state and local
governments for supplemental assistance.
o Maintaining close coordination with EPA Headquarters, the EPA Region IV
Office, U.S. Coast Guard District and Marine Safety Offices, State and local
•••Coordination Draft***
Revised July 18,1995 ESF-10-6
0241
-------
agencies, support agencies, the RRT and the organizations/structures
established upon activation of the Regional Response Plan.
o Ensuring that oil, hazardous substances, pollutants and contaminants
response activities are conducted pursuant to the NCP, RCP and
appropriate ACP(s).
C. ESF #10 Support Agencies: Support agencies are those Federal
departments or agencies designated to assist EPA with available resources,
capabilities or expertise in support of ESF #10 response operations. Each support
agency has duties established by statute, executive order or Presidential directive
which may be relevant to response actions under ESF #10. The ESF #10 Support
Agencies are listed at the beginning of this Appendix.
ESF #10 Support Agencies will be tasked as necessary to provide assistance in
their respective areas of expertise. Hie responsibilities applicable to ESF #10
support agencies are set forth at Sec. 300.175 of the NCP entitled Federal
agencies: additional responsibilities and assistance. There also may be missions
beyond the scope of the NCP that the Support Agencies may be tasked to perform.
D. EPA Support to Other ESFs; Activities within the scope of ESF #10 include
support to other ESFs as outlined in the FRP. The FRP directs EPA to provide
support to six ESFs. These are ESF #3, Public Works and Engineering, ESF #4,
Firefighting, ESF #5, Information and Planning, ESF #8, Health and Medical
Services, ESF #9, Uifean Search and Rescue and ESF #11, Food. In fulfilling
these responsibilities, EPA will be prepared to accomplish the following tasks as
assigned.
ESF #3: Public Works and Engineering
Primaiy Agency: U.S. Army Corps of Engineers
1. Assist in determining the suitability of water resources for human consumption
and identifying potential hazardous materials impacting drinking water supplies.
2. Provide technical assistance in assessing damage and restoration of water and
wastewater facilities.
3. Assist in locating disposal sites for debris clearance activities.
4. Provide air monitoring and debris segregation assistance for debris disposal by
open burning.
5. Provide safety guidance for areas affected by hazardous materials
•••Coordination Draft***
Revised July 18,1995 ESF-10-7
0242
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ESF #4: Firefighting
Primary Agency: Dept of Agriculture, Forest Service
Provide technical assistance and advice in the event of fires involving hazardous
substances.
ESF #5: Information and Planning
Primary Agency: Federal Emergency Management Agency.
Identify staff liaison or point of contact to provide damage and operational
information as well as technical expertise and advice on environmental issues.
ESF #8: Health and Medical Services
Primary Agency: Department of Health and Human Services
U.S. Public Health Service
Provide technical assistance and environmental information and expertise for
assessment of the health/medical aspects of situations involving hazardous
materials.
ESF #9: Urban Search and Rescue
Primary Agency. Federal Emergency Management Agency
Provide information on hazardous materials situations, consequence analysis and
hazards assessment of chemical releases that may impact Search and Rescue
operations.
ESF #11: Food
Primary Agency: Department of Agriculture
Assist with determining the suitability of food resources for human consumption
and identify potential hazardous materials impacts on the food supply.
CONCEPT OF OPERATIONS:
1. General: When disasters occur that are beyond the response capability of
state and local governments, the affected state requests a Presidential disaster
declaration. When the declaration occurs or in anticipation of this event, the
Federal Emergency Management Agency (FEMA) will activate the Federal
Response Plan (FRP).
Regional Federal agencies are grouped together under Emergency Support
Functions (ESFs) to facilitate the provision of Federal assistance to the state.
•~•Coordination Draft***
Revised July 18,1995 ESF-10-8
0243
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Each ESF has been assigned functional areas of responsibility in the ESF Annexes
to the Regional Response Plan. The ESFs have been further functionally
organized into branches to facilitate coordination of Federal assistance. The
primary agency for each ESF, with assistance from its support agencies, is
responsible for managing the activities of the ESF and ensuring that the approved
missions are accomplished.
Initial response coordination among the federal agencies takes place in the
Regional Operations Center (ROC). Linkage and initial coordination between the
affected State and the Federal agencies is accomplished by the Emergency
Response Team - Advanced (ERT-A) which deploys to the state Emergency
Operations Center.
If a disaster situation, such as a hurricane or impending flood, provides a warning
period, the ROC and ERT-A may be operational prior to the disaster. Following
landfall or within 72 hours of ROC/ERT-A activation and deployment, a Disaster
Field Office (DFO), located in the vicinity of the disaster area, will be established.
Once the DFO is operational, the ERT-A will deploy, along with their state
counterparts, to the DFO. Coordination functions that have been occurring at the
ROC will also be transferred to the DFO and most of the ROC staff usually
deploys to the DFO as well.
A Federal official from FEMA will be appointed as the Federal Coordinating
Officer (FCO). The FCO, operating from the DFO, is responsible for implementing
and coordinating emergency assistance and disaster relief to impacted states and
local communities. The ROC, ERT-A, FCO, DFO and other response structures
are described in detail in Appendices to this Annex.
2. ESF #10 Operations: Coordination functions required by the RRP are carried
out through the provisions of this Annex and under the direction of the EPA ESF
#10 Regional Chair. When response operations involve responses in the coastal
zone, the USCG District with jurisdiction in the affected area will designate a
USCG ESF #10 Vice Chair.
When a catastrophic event occurs, and upon receipt of notification that the RRP
and ESF #10 have been activated OR upon evaluation of a situation by the Region
IV ESF #10 Chair, the Chair will initiate notification, mobilization, deployment
and operations. The specific details and procedures to be used are included herein
as functional TABS.
When a catastrophic disaster situation involves an inland zone response only, the
predesignated EPA Region IV ESF #10 Chair will direct the response and provide
necessary staffing for the Regional Operations Center (ROC), the Emergency
~•"Coordination Draft***
Revised July 18,1995 ESF-10-9
0244
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Response Team - Advanced (ERT-A), the Field Assessment Team (FAsT) and the
Disaster Field Office (DFO).
When a response involves both the inland and coastal zones as defined in the
RCP, the predesignated ESF #10 Chair (EPA) will direct the inland area response.
Response operations in the coastal zone will be directed by the ESF #10 USCG
Vice-Chair. EPA and USCG representation to the ROC, ERT-A, FAsT and the
DFO will be determined jointly by the Chair and Vice-Chair.
If ESF #10 is activated for response operations occurring solely in the Region IV
coastal zone, all NCP guided response operations will be under the direction of the
USCG Vice Chair. EPA will staff the ROC, ERT-A and the DFO as required. The
Chair and Vice-Chair will determine what level of USCG staffing is necessary on
the ERT-A and in the DFO. If coastal operations are significant, the Vice-Chair
will be prepared to provide one or more USCG staff personnel to the DFO.
ADMINISTRATION AND LOGISTICS:
1. General: Resource management activities in support of an ESF #10
deployment are detailed in Appendix 5, Logistics and Funding.
2. Administration: Funding for pre-deployment operations conducted at FEMA
Region IVs direction/activation of ESF #10 and operations during a declared
disaster is provided on a reimbursable basis through FEMA from the Presidential
Disaster Fund. Funding and support agency accounting and reimbursement
procedures are detailed in Appendix 5.
3. Logistics:
A. Personnel: Personnel requirements required for an activation will fall into
one of three categories; field response OSCs, ESF #10 support staff and contractor
support to EPA OSCs from the Superfund Technical Assessment & Response
Team (START) and Emergency Response Contracting Service (ERCS). Contract
support to USCG, DOD and DOE OSCs will be in accordance with each lead
agencies' procedures and arrangements.
B. Equipment: OSCs will deploy with standard response equipment
supplemented as necessary. Appendix 5 provides guidance on response resources.
Response resources and equipment necessary to support START and ERCS
personnel will be the responsibility of the individual contractor.
~•~Coordination Draft***
Revised July 18,1995 ESF-10-10
02 4 S
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DIRECTION AND CONTROL:
1. Direction, and Control: All ESF #10 preparedness, and response operations
conducted in the inland zone and the coastal zone, will be under the overall
direction of the EPA ESF #10 Regional Chair.
When the disaster situation dictates that the US Coast Guard conduct NCP field
response operations in the coastal zone, as defined elsewhere in this plan, the
Coast Guard wOl provide direction and control of all coastal zone NCP response
operations.
When a disaster situation requires NCP field response operations in the inland
zone, as defined in this Plan, EPA will provide direction and control of all Inland
Zone response operations.
When a Department of Defense (DOD) or Department of Energy (DOE) facility is
affected by a disaster and releases of hazardous substances occur, the DOD or
DOE facility, in the role of lead agency, will provide OSCs as directed by the NCP.
When oil discharges occur on a federal facility, the facility will provide the first
federal official who will act for the appropriate OSC until his/her arrival.
The OSCs, provided by EPA, USCG, DOE or DOD, as specified in the NCP, will
direct the ESF #10 field response operations.
The ESF #10 Chair will insure that all actions taken under the direction of EPA,
USCG, DOD and DOE OSCs are coordinated within the overall context of disaster
response operations as directed by the FRP/RRP. Each agency providing an OSC
will establish coordinating mechanisms to ensure that their OSC directed field
response operations are coordinated with the Regional ESF #10 Chair.
2. Coordination: Coordination within EPA, with the U.S. Coast Guard, other
Federal Agencies and organizations will be carried out as established under this
Annex.
3. Facilities: The Regional Response Center, located in the EPA Region Office in
Atlanta, will be the Command and Coordination Center. EPA field operations will
be coordinated from the EPA Mobile Command Post. USCG fixed and mobile
facilities will be described and utilized as indicated in the USCG District and
Marine Safety Office Operations Plans.
•~•Coordination Draft**"*
Revised July 18,1995 ESF-10-11
02 4 6
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APPENDIX 1: EMERGENCY RESPONSE ORGANIZATIONS:
1. Purpose:
This appendix describes the National and Regional elements and
organizations that are involved in the implementation of ESF #10. Some of
these are existing elements of the National Response System as created by
the National Contingency Plan. These elements are discussed in detail
elsewhere in this plan. Other structures and organizations have been
developed exclusively to implement the FRP. These FRP relevant elements
will be defined in this Appendix and the details of their operation will be
described in Appendix 3, OPERATIONS. Figure 1 in this appendix
illustrates the elements, both NRS and FRP, that are likely to be involved
during a FRP activation.
2. National-Level Response Support Elements:
At the EPA HQ level, ESF #10 is implemented by the Director, Chemical
Emergency Preparedness and Prevention Office (CEPPO) who is the ESF
#10 National Chair and who also serves as the Chair of the National
Response Team.
National Response Team (NRT): The NRT is the primary vehicle for
national planning and for coordinating Federal agency activities under the
NCP. The ESF #10 Chair consults with the NRT for advice and assistance
in carrying out activities under ESF # 10.
Catastrophic Disaster Response Group (CDRG): The CDRG is the
headquarters-level coordinating group which addresses policy and response
issues that require national-level decisions or policy direction. The CDRG is
chaired by a FEMA Associate Director and includes representatives from
the Federal departments and agencies that have responsibilities under the
FRP. The ESF #10 National Chair or a designated alternate represents
ESF #10 on the CDRG.
Emergency Support Team (EST): The EST is the national interagency
organization, composed of ESF representatives at the national level. The
EST operates from FEMA headquarters to provide support for the FCO and
the Emergency Response Team. A predesignated EPA Headquarters
representative represents ESF #10 on the EST.
Revised July IS, 1995
•••CoonBfnation Draft*** ESF-10-1-1
0247
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3. Region IV Response Support Elements:
At the regional level both command and control and field on-scene
operations take place. EPA Region IV is the Regional ESF #10 primary
agency and the Chief, Emergency Response and Removal Branch is the
designated ESF #10 Chair. The Regional Chair also serves as the Co-Chair
of the Region IV RRT.
Regional Intent fWdinsition Team (RiCT): The RICT is an EPA
intra-regional organization of senior stafFmanagement representatives from
each of the EPA Region IV Divisions and Offices. The RICT is the focal
point for overall coordination of the region's response efforts. It also
provides the support to requests for resources and technical assistance as a
part of EPA's support role to other ESFs during a FRP activation. The
RICT Chair is the Regional ESF #10 Chair.
Region IV Regional Response Team (RRT): The RRT is made up of
regional representatives of the Federal agencies on the NRT as well as
representatives from each state within the region. The RRT is co-chaired by
EPA and the USCG. The EPA Co-Chair is the ESF #10 Chair; the USCG
Co-Chair is the Chief of the USCG 7th District Marine Safety Division. Hie
RRT serves as a regional planning and preparedness organization prior to a
response, provides a mechanism for coordinating resources and provides
advice and assistance to the On-Scene Coordinators (OSCs) during response
actions. The federal agencies that are designated support agencies to ESF
#10 are also member agencies of the RRT. In most cases the same
individuals represent their agency on both the Emergency Response Team
(see below) and the RRT.
Emergency Response Team (ERT): The ERT is the basic organizational
tool at the regional level for delivery of Federal response and recovery
assistance during a FRP activation. The ERT is an interagency group
composed of representatives of each of the ESFs and FEMA staff. The ERT
provides communications, administrative, logistical and operational support
to the regional response activities in the field.
In the initial phases of a disaster response, an Emergency Response Team -
Advance (ERT-A), which is a smaller, streamlined element of the ERT is the
initial group to respond to the field. The ERT-A usually deploys to the
State Emergency Operations Center (EOC) and subsequently forms the
nucleus of the Ml ERT which operates from the Disaster Field Office (DFO)
once the DFO is established.
Reviled July IS, 1995
***Coorfifoiit»on Draft*" ESF-10-1-2
02 4 8
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Field Assessment Tgam (FAsT)i The FAsT team provides immediate
field information on the extent of the disaster area and identifies what
resources are needed to save lives and protect property. The Federal FAsT
teams are to supplement State capabilities, however, if a State is
overwhelmed, very little or no state support and participation can be
expected. The FAsT Team will be activated and deployed by FEMA at the
request of the state. An EPA OSC will be designated as the ESF #10
member of the Regional FAsT Team, either as a part of the pre-deployment
mobilization, or in case of a catastrophic no-notice event, as soon as FEMA
activates the team.
Federal Coordinating Officer (FCO): The FCO is a senior FEMA
regional official appointed on behalf of the President by the FEMA National
Director. The FCO manages and coordinates the overall Federal response
through the interagency ERT and works closely with the State Coordinating
Officer to determine state support requirements. Hie FCO tasks ESFs to
perform missions to supplement state resources and capabilities. If a
disasters) affects multiple states, a FCO is appointed for each state.
Disaster Field Office (PFO): A DFO is established in or near the
affected area and provides a facility for the ERT and the state agencies to
coordinate the disaster response. The DFO is essentially the disaster
operations center. If the disaster affects multiple states, a DFO is
established for each state. The DFO contains office space, equipment and
communications.
Revised July 18, 1995
•"Coordifoation Draft***
ESP-10-1-3
02 4 9
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3F # 10 HAZARDOUS MATERIALS/ENVIRONMENTAL EMERGENCIES
NATIONAL AND REGIONAL
ORGANIZATIONS
1AT1QNAL
National ESF #10 Chair:
Director, Chemical Emergency
Preparedness and Prevention
Office, US EPA
[Catastrophic Disaster j
{Response Group
l(CPRG)
[B4ERGENCY SUPPORT
TEAM (EST)
sis:
EGIONAL
U.S
COAST
GUARD
DISTRICT
REGIONAL ESF # 10 CHAIR
Chief, EPA Emergency Response
& Removal Branch
REGIONAL ESF #10 VICE-CHAIR
U.S. COAST GUARD 7th DISTRICT ,
Marine Safety Division
. x.7 A_/'; v
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Regional Incident Coord
Team (RIOT)
REGIONAL
OPERATIONS
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FEMA
REGIONAL
RESPONSE
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EMERGENCY
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(ADVANCE)
DISTRICT
OPERATIONS IUSCG
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Clean-up Contractors
Figure 1. Nationa, 'id Regier.-' —anua-'cns
02 30
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Appendix 2, Notification and Mobilization to Annex P
Appendix 2: NOTIFICATION AND MOBILIZATION
1. General:
Certain situations, such as a hurricane or flood, provide a warning period.
Upon receipt of an Activation Order from FEMA Region IV, or, based on the
planning assumption that incidents involving oil and hazardous substances are
likely to occur, the ESF #10 Chair or designated Chair will activate ESF #10
and initiate actions to ensure that ESF #10 becomes operational within two
hours.
When a no-warning event occurs, notification of the event and activation of the
FRP will likely be received from the FEMA Regional Office.
2. Notification Procedures:
The EPA Region IV Emergency Response Telephone Duty Officer is the 24
hour point of contact for ESF # 10. All communications pertaining to alert,
activation or operations prior to the activation of the Regional Response Center
should be made through the 24 hour emergency number; (404) 347-4062.
Following activation of the Regional Response Center, located in the EPA
Regional Office, 345 Courtland St. Atlanta, GA., alternative telephone contact
numbers will be provided to support agencies and FEMA. During the conduct
of response operations under an RRP activation, the established 24 hour
emergency number will revert to receipt of emergency calls not pertaining to
the disaster and will NOT be used unless authorized by the ESF #10 Chair.
Following receipt of an alert or notification from FEMA Region IV, activating
the Regional Response Plan and ESF #10, or activation of ESF #10 alone, the
Telephone Duty OSC will immediately begin the following notifications. If the
Regional Chair cannot be immediately contacted, the Duty Officer will attempt
to contact one of the ERRB Section Chiefs beginning with the Emergency
Response Section. The internal ERRB notification schematic is shown in figure
2.
(1). Chief, Emergency Response and Removal Branch,
(ESF #10 Chair).
(2) Chief, Emergency Response Section, ERRB,
(Alternate Chair, ESF #10)
Revised July 18,1996
•"•Coordination Draft*** ESF #10-2-1
0 2 5 i
-------
(3)
Chief, Removal Operations Section, ERRB.
3. Mobilization Procedures:
At the direction of the ESF #10 Chair/Alternate Chair, the Duty Officer will
begin actions to alert ERRB and TAT personnel. All personnel contacted will
be instructed to remain on standby for mobilization or will be directed to
mobilize if ordered by the ESF #10 Chair. The Duty will begin the following
actions using the detailed procedures in the ERRB "Blue Book".
* Determine availability of OSCs and alert them for potential deployment.
Contact and determine availability of pre-designated ERRB personnel
to deploy to the Regional Operations Center and with ERT-A. Deploy
upon order from the ESF 10 Chair.
Alert/mobilize staff to the Regional Response Center.
Alert/mobilize and deploy TAT assets and the Mobile Command Post.
TAT will be prepared to immediately mobilize and deploy a minimum
of four (4) TAT response personnel, the MCP, an equipment vehicle and
a chase vehicle.
Reviand July 18,1995
•**Coordi nation Draft***
ESF #10-2-2
0 2 52
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REGION IV EMERGENCY SUPPORT FUNCTION # 10
(ESF #10)
ALERT/NOTIFICATION PROCEDURE
ymmmmmmmrnUA
llll FEMA REGION'''lV 1
REGIONAL INCIDENT
COORDINATION TEAM
£
CHIEF,
EMERGENCY RESPONSE
SECTION
2K
OSCs
TAT
RRC & ROC
STAFF
EPA REGION IV
TELEPHONE DUTY OSC
(24 HR)
CHIEF, ERRB
DIRECTOR,
WASTE MGT DIV
CHIEF,
REMOVAL OPERATIONS
SECTION
1
RA
DRA
CHIEF,
REMOVAL MANAGEMENT
SECTION
OSCs
Figure 2, Alert/Notification
= SF *
0253
-------
FEDERAL RESPONSE PLAN)
REGION IV EMERGENCY SUPPORT FUNCTION # 10
(ESF #10)
ALERT/NOTIFICATION PROCEDURE
EXTERNAL
REGIONAL RESPONSE
CENTER
EPA HEADQUARTERS
EMERGENCY
OPERATIONS
CB^Tm
ESF # 10
SUPPORT
AGENCIES
REGION IV
REGIONAL
RESPONSE
TEAM
EPA BACKUP REGION
Figure 3. ESF #10 Externa! Notification
ESF #10 2-4
0254
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Appendix 3, Re«poo»e Operations, to Annex R
RESPONSE OPERATIONS;
PURPOSE: This Appendix describes the classifications of disaster magnitude,
actions to be taken in activation, deployment, coordination and response to a
catastrophic event and the elements of the Regional Response Plan (RRP) which
are applicable to EFS #10,
Annex E, OPERATIONS, to the FEMA Regional Response Plan (RRP) provides the
generic guidance for disaster response operations. The portions of that guidance
that are applicable to ESF #10 are repeated in this Appendix.
DISASTER MAGNITUDES: The severity of an actual or impending disaster is
characterized by assigning a disaster magnitude level. These levels, numbered 1,
2, or 3, indicate the severity or potential severity of the event. These levels also
serve to indicate the type of interagency response required through the FRP.
Level 1: The smallest of the events. May result in a declaration. Some Federal
involvement may be requested by the State and local jurisdictions. Federal
assistance may include only one of two ESFs with special technical capabilities
and/or the FEMA "traditional recovery" programs such as Individual Assistance
(IA) and/or Public Assistance (PA). Traditionally, ESF #10 is not activated at this
level. If oil and/or hazardous substances spills do occur, response operations will
be conducted under the procedures in the NOP, RCP and appropriate ACP.
Level 2: The event may result in a declaration with moderate Federal assistance.
ESF #10 may be activated and EPA Region IV may be tasked to provide technical
assistance to another ESF.
Level 3: A catastrophic event which will very likely result in a disaster
declaration. The activation and deployment of the operational elements and
systems of the RRP, ESF #10 and large scale Federal assistance is very likely.
By use of disaster magnitudes, the current operational mode will be described by
the phase and level of magnitude. For example, Readiness Phase - Level 3 would
indicate an anticipated catastrophic event such as a Category 5 hurricane
threatening a densely populated area.
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••~COORDINATION DRAFT*** ESF #10-3-1
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CONCEPT OF OPERATIONS:
Alert and Notification;
FEMA Region IV will notify EPA and other Federal Agencies of potential or actual
events using the following formats.
Advisory: - Made oil a day to day basis while in a normal state of preparedness.
In the event of a potentially catastrophic situation, an Advisory notification is
issued for informational purposes only. No formal action by EPA or ESF #10 is
required.
Warning: - When an event has occurred or is imminent that may cause activation
of the FRP, a Warning notification is issued.
Activation: - FEMA Region IV issues an Activation notification when a
catastrophic disaster or emergency has occurred or is imminent that will require
Federal response operations under the FRP. This notification, which activates
ESF #10 when received by EPA Region IV, is initially received verbally and is
followed by a written activation order.
Cancellation: - Previously issued Advisories or Warnings are canceled by FEMA
through a Cancellation notice. A Cancellation notification may also be used to
cancel a prior Activation if necessary before Federal response operations have
been established.
Organization:
A common operating framework is essential to facilitate the delivery of Federal
response assistance to help States deal with the consequences of disasters.
Response operations conducted under the Riff involve several unique
organizations and operations. These entities emerge as the disaster situation
unfolds and provided the necessary mechanisms to conduct and coordinate RRP
operations. These entities include the Regional Operations Center (ROC), the
Emergency Response Team - Advanced (ERT-A), the Field Assessment Team
(FAsT), and the Disaster Field Office (DFO). Each of these is described in the
TABs A-D to this Appendix. The EPA response organizations, functions and
structures that are applicable to disaster response are described in TABs E and F
and in Appendix 1.
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Regional Response Plan Operations:
Depending on the situation and type of actual or impending disaster, FEMA
Region IV will activate the ROC as the initial Federal Emergency Operations
Center. The ROC facilitates early response coordination among the federal
agencies that make up the Emergency Response Team (ERT),
At the State level, initial coordination between the affected State and the Federal
agencies is accomplished by an advanced element of the Emergency Response
Team, called the ERT-A, ( Emergency Response Team - Advanced) which deploys
to the State Emergency Operations Center.
If a disaster situation, such as a hurricane or impending flood, provides a warning
period, the ROC and ERT-A may be activated prior to the disaster. If the disaster
situation requires continued Federal assistance, a Disaster Field Office (DFO) will
be established in the vicinity of the disaster area. Once the DFO is operational,
the ERT-A will deploy, along with their State counterparts, to the DFO.
Coordination functions that have been occurring at the ROC will also be
transferred to the DFO and most of the ROC staff usually deploys to the DFO as
well.
A Federal official from FEMA will be appointed as the Federal Coordinating
Officer (FCO). The FCO is the senior Federal Official, appointed to act for the
President and is responsible for managing, implementing and coordinating the
overall Federal assistance and disaster relief to impacted states and local
communities. The ERT works for and in cooperation with the FCO.
ESF #10 Alert/Notification Operations:
EPA Region IV begins ESF #10 activities upon receipt from FEMA Region IV of an
Advisory and/or Warning if time allows or immediately upon receipt of an
Activation notification for a sudden, no-warning event.
The EPA Telephone OSC (TEL) receives the alert/notification via the Region IV 24
hour number and begins the actions described below. These instructions and
procedures are detailed further in the ERRB Blue Book. Section I: Response to
Call-Down Alert Notifications.
ADVISORY notification:
FEMA issues an Advisory notification for informational purposes only. Upon
receipt the TEL will notify the ERRB Branch Chief. No other actions are required
unless directed by the Chief, ERRB.
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WARNING notification: An event has occurred or is imminent that may require
response operations. The TEL receives the Warning notification from FEMA
Region IV and takes the following actions:
1. Notifications:
Chief, ERRB (ESF #10 Chair)
Chief, Emergency Response Section (ESF #10 Alternate
Chair)
Chief, Removal Operations Section
Regional Response Center Coordinator
2. At the direction of the ESF #10 Chair/Alternate Chair, the TEL will
begin the following actions:
Determine availability of OSCs and alert them for potential
deployment.
Contact and determine availability of pre-designated ERRB personnel
to deploy to the Regional Operations Center and with ERT-A.
Alert the Regional Response Center staff.
Alert START and task them to prepare the Mobile Command Post for
deployment and prepare a listing and status of available START
personnel and vehicles.
All personnel contacted will be instructed to remain on standby for
mobilization or will be directed to mobilize if ordered by the ESF #10 Chair.
ACTIVATION notification:
1. Begin notification sequence as listed in paragraphs 1 and 2 above.
2. Contact available and/or predetermined OSCs and provide
deployment/mobilization instructions from the ERRB Chief.
3. Notify the R-2 OSC to report to the RRC. If the R-2 has been deployed,
notify any available OSC to report to the RRC to assist with the
mobilization process.
4. Conduct other duties listed in the BLUE BOOK or as directed by the
ESF #10 Chair,
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•••COORDINATION DRAFT*** ESF #10-3-4
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5. Notify the Atlanta START of the status of the event. START will be
prepared to mobilize and deploy a minimum of four (4) response personnel,
the Mobile Command Post (MCP), an equipment vehicle and a chase vehicle
within 4 hours,
6. The Regional Response Center, located in the EPA Regional Office, 345
Courtland St. Atlanta, GA., will be activated by the REC Coordinator and a
START member. Initial staffing is shown in TAB E, figure 5.
ESF #10 Field Response Operations:
Upon activation of ESF #10, two phases of response operations are initiated.
Phase One involves the coordination and interaction with other members of the
ERT, FEMA, State and local officials and the RICT. Phase Two is the tactical on-
scene operation in the field. The initial field operations in the impacted area will
be the damage assessments conducted by the Field Assessment Team (FAsT). See
TAB C for details. Also included in this phase are field responses by other EPA
Region IV staff in a technical support role to other ESFs. These two phases
operate concurrently throughout the disaster response phase and are deactivated
when their functions are no longer needed.
Through the provisions of the NCP, EPA, the US Coast Guard, the Department of
Defense and the Department of Energy share the responsibility for responses to
releases of hazardous substances. EPA and the USCG have responsibility for
responses to all oil discharges. Field responses to situations involving the
discharge of oil or releases of hazardous substances will be directed or managed by
an OSC. As provided in the NCP, EPA will provide the OSC for situations
occurring in the inland zone. The USCG will provide the OSC for responses in the
coastal zone.
Releases or evidence of releases detected from FAsT aerial overflights will
generally require an on-the-ground assessment. These initial assessments, both
air and ground are considered a part of the tactical ground response. Following
the assessment of damage and detection of discharges and releases a prioritization
of responses may be required. All available data will be assembled and reviewed
by the IOSC and the on site OSC teams. If priorities are necessary, the IOSC, in
conjunction with State and local responders if they are available, will determine
the priorities of response operations. Hie IOSC will provide this information to
the DFO and the RRC. Situations involving releases or threats of releases of
hazardous substances located on or from DOD or DOE facilities will be
coordinated with the appropriate DOD or DOE organization by the ESF #10
Chair.
July 18, 1995
"~COORDINATION DRAFT*** ESF #10-3-5
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TAB A: Regional Operations Center, to Appeodiic 3, Operations
REGIONAL OPERATIONS CENTER (ROC)
INTRODUCTION:
The "Regional Operations Center" (ROC) is the first multi-agency location
activated and its main purpose is to provide the physical means and location for
coordinating the initial Federal response efforts.
The ROC is located in the FEMA Regional Office in Atlanta, GA. Initial staffing
is by members of the FEMA Regional Operations Support Team (ROST) and those
ESFs considered appropriate by the FEMA Regional Director. Activation of some
or all of the ESFs depends on the type, location and magnitude of the disaster or
impending disaster.
The ROC remains active until such time as a Disaster Field Office is operational
and occupied by the Regional Emergency Response Team (ERT).
PLANNING:
Any event that is sufficient to cause the FRP to be activated will result in the
activation of the ROC. The ROC, depending of the disaster situation, may be
operational on a 24-hour basis during the initial phase of operations. It required,
the ROC may remain operational for the duration of the emergency.
FEMA has established a "Readiness Standard" for the ROC. If activated during
duty hours, the ROC will be operational within two hours. If activated during
non-duty hours, the ROC will be fully operational within four hours. If special
conditions preclude the use of the Atlanta ROC, the Federal Regional Center in
Thomasville, GA will be the ROC alternate location. If this occurs, times required
to deploy the ERT will be considered.
CONCEPT OF OPERATIONS;
The ROC may be activated by FEMA upon receipt of notification that an event has
occurred that may require Federal assistance to the affected State(s). FEMA may
also activate the ROC in anticipation of an incident, such as an approaching
hurricane, when it can be readily assumed that Federal aid may be required.
The ROC Director is normally the Deputy FEMA Regional Director. The ROC
Director manages operations until a determination has been made that Federal
July 18,1995
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assistance will not be required or until the Federal Coordinating Officer assumes
responsibility for coordinating Federal activities.
The rapid deployment of the Emergency Response Team - Advanced (ERT-A) to
the affected State to begin direct liaison with the state agencies is critical to the
implementation of the Federal response. Hie ROC directly supports all efforts to
activate and deploy the ERT-A. The ERT-A will mobilize in the ROC and deploy
to a location in the affected state, usually the State Emergency Operations Center
(EOC).
If the disaster affects multiple states, the ROC will coordinate all activities and
will deploy an ERT-A to each affected state.
ESF #10 EOC Operations:
The ERRB Emergency Preparedness Coordinator is the pre-designated ESF #10
representative in the ROC. If this individual is unavailable, the ESF #10 Chair
will designate an OSC as an alternate. In the Activation Order, FEMA Region IV
will provide the date/time for ESF representatives to report to the ROC.
1. Staffing of the ROC will initially consist of one ERRB member and one
START contractor. Additional staffing may be required if the situation requires
24-hour operation.
2. The ROC is located in the FEMA Region IV offices at 1371 Peachtree St,
7th floor, Atlanta. Upon arrival, show your EPA ID and sign in as the ESF #10
representative. You will be directed to the FEMA Training room. When you enter
the room, locate the Emergency Services Branch (ESB) and report to the ESB
Chief. A sign usually indicates the location.
3. As shown in figure 4., four ESFs; ESF-4, Firefighting; ESF-8, Health and
Medical Services; ESF-9, Urban Search and Rescue; and ESF-10 make up the
Emergency Sendees Branch. A FEMA staff member has been preassigned as the
ESB Chief and is responsible for assisting their assigned ESFs in their efforts to
complete their assigned mission assignments.
4. As soon as possible after arrival, establish telephone contact with the
Regional Response Center. At least one telephone line and a computer connected
to the ROC LAN will be available. Verify the telephone number by having the
RRC call back on the listed number.
5. A primary function of the ROC is to provide direct linkages with the other
ESFs that have been activated. Direct person-to-person coordination and
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information exchange is simplified in this mechanism. Each ESF in the ROC is
also responsible for providing input to the FEMA Situation Report (SITREP). This
SITREP is usually produced twice each day. Specific instructions are provided by
the FEMA ROC staff. If more than one telephone line is available, either at the
ESF #10 desk or within the FEMA offices, a laptop computer and fax modem
should prove useful. A chronological log of events which provides information for
input into the FEMA SITREP can be kept on the laptop and faxed to the RRC for
input to the ESF #10 SITREP.
6. In addition to the activation of the Regional Response Center, two other
functions involving ESF #10 participation will be deploying to locations in the
affected state(s). The deployment of the Advanced element of the ERT (ERT-A) to
the State Emergency Operations Center and the deployment of the Field
Assessment Team (FAsT) will occur soon after the ROC is activated. Once the
ERT-A ESF #10 is established, establish telephone contact and exchange
telephone numbers. Past experience has shown that a twice daily conference call
between the ROC, ERT-A and the RRC is very useful.
7. Usually, activation of the ROC, the ERT-A and the FAsT is followed by the
establishment of a Disaster Field Office (DFO) in the affected state(s) (usually
about 72 hours after the disaster). The DFO is normally as close as possible to
the impacted area. The ERT-A at the state EOC redeploys to the DFO and the
majority of the ROC staff, both FEMA and the ESFs are also deployed to the DFO.
When Mly operational, ail of the activated ESFs will have deployed to the DFO
and the coordination and the management of the Federal response and assistance
continues at the DFO.
The ESF #10 staffing in the DFO will be determined by the ESF #10 Chair. See
TAB D for details on DFO staffing and operations.
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FEDERAL RESPONSE PLAN
REGIONAL OPERATIONS CENTER (ROC)
H - 24 TO H * 72
REGIONAL OPERATIONS CENTER (ROC)
FEMA REGIONAL OFFICE
Peachtree St. N. E., Suite 700
Atlanta, GA 30309
C ESF # 6
ESF #1
( ESF #2
ESF #11
INFORMATION
AND
PLANNING
ESF #7
Human Needs
Operations
Support
ESF #4
ESF #3
ESF #8
ESF # 12
ESF #9
ESF # 10
HAZARDOUS
MATERIALS
Emergency Services
Infrastructure
\J^Support
ESFs That EPA Supports
Figure 4. Regional Oper ' •; 3 . n.er
02 G 3
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TAB B: Emergency Response Team - Advanced, to Appendix 3, Operations
Emergency Response Team - Advanced (ERT-A):
INTRODUCTION:
The Regional Federal Agencies signatory to the FRP have been grouped together
under Emergency Support Functions (ESFs) to facilitate the provision of Federal
assistance to the State(s). The full Emergency Response Team (ERT) includes
representatives from each of the ESFs and staff from the FEMA region. The ERT
is the basic organizational tool for delivery of Federal response and recovery
assistance.
The initial element of the ERT to deploy is the ERT-A which is a streamlined
advance element of the full ERT which deploys to the affected State.
The ERT-A has a number of responsibilities, the most important of which is to
establish an immediate Federal presence with state agency counterparts to
determine the magnitude of the disaster situation. The ERT-A also determines
whether a Ml or partial ERT will be needed, coordinates the FAsT Teams and
establishes the Disaster Field Office.
ORGANIZATION:
1. The ERT-A operates under the control of the ERT-A Team Leader who is
appointed by the FEMA Regional Director. In most instances, the ERT-A Team
Leader is the predesignated Federal Coordinating Officer (FCO). The ERT-A
consists of predesignated key FEMA regional staff members, ESF Primary Agency
representatives, military support and may include Regional or National FAsT
(Field Assessment Team) Teams.
2. The ESF #10 portion of the ERT-A will consist of an OSC and a START
contractor. The team will be augmented with more staff if necessary.
PLANNING:
1. The ERT-A will operate from the State EOC until the Full ERT is operational
at the DFO. Because of the limited space available in most of the State EOCs in
Region IV, minimum staffing is necessary.
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~•~COORDINATION DRAFT*** ESF #10-3-9
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2. The ERT-A will be prepared to deploy within three hours of notification of a
catastrophic disaster or as directed by the FEMA Regional Director. Mode of
travel will be determined by FEMA.
3. If a disaster affecting multiple states in Region IV occurs, an ERT-A will be
staffed and deploy to each affected states. A planning figure of a maximum of
three teams will be used.
CONCEPT OF OPERATIONS:
JL. Notification: FEMA Region IV will notify the ESF #10 Chair of activation
and when and where deployment of the ERT-A will occur. ESF #10 will be given
a reporting time, location and method of transport (group vs. individual). Hie
ERT-A may meet initially in the ROC and deploy as a group or individual ERT-A
members may be directed to deploy to a common meeting location in the state.
2. EOC Operations: Upon arrival, the ESF #10 member should establish
face-to-face contact with the State ESF #10 counterpart
to coordinate damage and needs assessments and initial field operations.
The ESF #10 ERT-A member should contact the RRC as soon after arrival as
possible and provide a telephone contact number. Have the RRC call you back
immediately to verify contact. Obtain the ROC telephone number from the RRC
and make direct contact with the ESF #10 desk at the ROC. A twice daily
conference call will be set up by the RRC.
Any information, requests for support or operational information pertaining to
known or suspected releases of oil and/or hazardous substances should be passed
to the RRC and the ROC as quickly as possible. Decisions as to deployment,
responses to releases and uses of resources will be made by the Regional ESF #10
Chair.
When the DFO is operational, the ERT-A staff will join the ROC staff at the DFO
to staff the DFO as part of the full ERT. At that time the ERT-A ceases to exist.
July 18, 1995
"•COORDINATION DRAFT*** ESF #10-3-10
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TAB C: Field Assessment Team (FAsT), to Appendix 3, Operations
FIELD ASSESSMENT TEAM (FAsT)
INTRODUCTION:
The FAsT Team was established to provide immediate field information on the
extent of the disaster area and to identify the resources needed to save lives and
protect property. The Regional FAsT Team is intended to supplement the State
capabilities in conducting this assessment, however, if a State is overwhelmed,
this mission may be accomplished with very little State support.
PLANNING:
The Regional FAsT Team will be directed by the FAsT Team Leader appointed by
the FEMA Regional Director or by the ERT-A Team Leader. The Regional FAsT
Team is normally composed of 9 members; the Team Leader and two FEMA
documentation and logistics personnel, a State Emergency Management Agency
representative
and five personnel from other Federal agencies representing the ESFs. ESF #10
has one position on the Regional FAsT Team.
The ESF #10 representative to the Regional FAsT Team will be an OSC
designated by the ESF #10 Chair. If possible, this individual will be the
designated Incident OSC for subsequent operations.
The FAsT Team will be prepared to deploy within 6 hours of activation and start
assessment activities within 12 hours of a no-notice event.
Because it is unlikely that the Regional FAsT Team can accommodate USC6
assessment requirements for coastal zone discharges of oil, the affected USCG
District should make arrangements to conduct surveillance and assessments in
the coastal zone as required.
CONCEPT OF OPERATIONS:
Notification: FEMA will notify the ESF #10 Chair that the Regional FAsT
Team has been activated and provide deployment instructions. When activated,
FAsT Team members will be told the location of a staging area or Base of
Operations, reporting time, method of travel and name of the FAsT Team Leader
Deployment: Under most circumstances, each FAsT Team member should travel
independently to the Base of Operations. They should bring their personal {24
hour) life support package with them.
July 18,1995
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If the reporting time at the FEMA Staging Area allows ground travel, the ESF
#10 FAsT Team OSC and the Advance Teams will travel by ERRB and START
vehicles to the designated Staging Area. If the situation requires deployment of
the ESF #10 FAsT Team member by air, the remainder of the ESF #10 FAsT
Team will deploy via ERRB response vehicles. The response vehicles will be
equipped with cellular/satellite phones, HF/SSB and VHF radios.
START will mobilize the EPA mobile command post and a minimum of two chase
vehicles. These units will travel to the staging area and be prepared to
participate in any follow-up damage/needs assessment and field operations.
Under some circumstances, some or all of these units may be airlifted into the site
by military air.
Regional FAsT Team Operations:
The initial entry into the disaster area is usually made by the Regional FAsT
Team. ESF #10 has one representative on this team. Initial FAsT Team
assessments are conducted by helicopters supplied by the military or state
National Guard. Representatives from several ESFs are usually in the same
aircraft. As a result, only a broad overview of the disaster site is possible and it
may not allow the ESF #10 FAsT Team member to adequately survey actual or
potential spill sites. Subsequent helicopter surveillance may be required.
During the overflight, several stops are usually made to confer with local officials.
In some cases, it may be possible to survey parts of the area with local officials.
Personnel at the local level who are most familiar with hazardous materials
locations, problems or potential problems include the Fire Chief and/or members of
the Local Emergency Planning Committee (LEPC) if one exists.
The results of the FAsT Team initial assessment are recorded on a standard form
and submitted to the Team leader. This information is transmitted electronically
to the ERT-A at the State EOC and to the ROC.
ESF #10 Assessment Operations:
To support the ESF #10 OSC on the Regional FAsT Team, the Mobile Command
Post and one or more Advance Teams will be deployed via ERRB and START
vehicles to the disaster site to conduct further ground and aerial surveillance and
assessment.
When overflight operations are concluded, the ESF #10 FAsT Team OSC will
return to the staging area or other predesignated area and rendezvous with the
OSC Advance Teams and START contractor support assets. When both of these
July 18, 1995
•••COORDINATION DRAFT*** ESF #10-3-12
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units meet, the FAst Team OSC becomes the Incident OSC (IOSC). The Advance
Teams, under the direction of the IOSC, will begin follow-up damage/needs
assessments involving field surveys of the affected area with state and local
responders to the extent they can participate. If the initial FAST assessment
overflights or other information indicate a need for further aerial assessment, the
ESF #10 Chair will authorize use of the pre-established helicopter rental contract.
This phase of ESF #10 operations will focus on immediate, time-sensitive
emergency needs and actions to include:
Investigating potential for damage/destruction to petroleum
storage/distribution facilities, petrochemical facilities and industrial
complexes with potential for HAZMAT releases. Special attention will be
given to fires and their potential for involvement of chemicals.
Assessment of damage to ports, harbors and harbor facilities with potential
for discharges/releases.
Assessment of transportation terminals including rail, highway transport
and pipelines.
Establishing contact with the ESF #10 ERT-A personnel at the State
EOC(s) to acquire and assess reports of releases/discharges from local EOCs
and other sources available to the State.
July 18,1995
~••COORDINATION DRAFT***
ESF #10-3-13
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TAB D, Disaster Field Office, to Appeodix 3, Operations
DISASTER FIELD OFFICE (DFO)
INTRODUCTION:
The DFO is the primary field location for the coordination of response and
recovery operations in an affected State. In multiple state disasters, a DFO will
be established in each State. The DFO is a Multiple Support Facility designed to
support the Emergency Response Team (ERT) to include the Federal Coordinating
Officer (FCO), State Coordinating Officer (SCO), their Federal and State staffs,
the activities of multiple joint Federal/State Emergency Support Functions (ESFs)
and other Federal, State, local and voluntary agencies and activities.
The DFO established when a disaster declaration has been issued and is located
in a facility located in the immediate vicinity of the disaster site. Normally, the
DFO will be operational within 72 hours of the disaster declaration. The location
selected for the DFO must have space, layout, heating and air conditioning,
electricity and water. The magnitude of the disaster will determine the size of the
DFO.
DFO OPERATIONS:
1. General Response Activities:
The DFO will normally operate 24-hours a day using two 12-hour shifts. The ESF
#10 operations may not be required on a 24 hour basis. Staffing requirements and
operational times for the ESF #10 function will be determined by the ESF #10
DFO Team Chief in consultation with the FEMA Emergency Services Branch
Chief.
DFO sign-in procedures and an in-processing briefing will be given to all ERT
members when they check in to the DFO.
2. ESF #10 DFO Operations:
Organization and Staffing: Hie ESF #10 representatives in the DFO are
traditionally the ESF #10 representatives from the ROC and the ERT-A who move
to the DFO as the ROC and ERT-A are phased out and operational control reverts
to the DFO. Under full DFO staffing, the ESF #10 DFO Team will be under the
direction of the Emergency Response Section Chief or other individual appointed
by the ESF #10 Chair. In a minimal DFO staffing, the ERT-A member will be the
DFO Team Chief.
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The minimal DFO staffing will be two EERB members and two START
contractors. Depending on the magnitude of the disaster and the actual or
anticipated work load, additional staffing may be required. This will be
determined on a case-by-case basis by the ESF #10 Chair. Attachment 1 to the
TAB provides details on DFO space needed, communications, equipment and
supplies and the materials in the DFO "Go-Kit".
Figure 3. illustrates a full DFO staffing pattern which includes representative of
other EPA Region IV Divisions and Offices which have been assigned missions
through the Regional Incident Coordination Team (RICT) in response to a tasking
received from one of the ESF s supported by EPA.
When events require US Coast Guard (USCG) response operations in the coastal
zone, a USCG liaison to the DFO may be deployed as agreed by the ESF #10 and
the USCG District involved.
Operations: As soon as the ESF #10 DFO Team is operational, contact will be
made with the Regional Response Center to provide voice and fax line telephone
numbers and determine, if necessary, which unlisted line in the RRC will be used
by the DFO. The DFO will also make contact with the Mobile Command Post and
determine the best, most reliable way of communicating.
A twice daily conference call among the RRC, DFO and MCP will be held unless
otherwise determined by the ESF #10 Chair. The DFO and the MCP will
maintain an operations log and will provide input to the RRC for the daily
SITREP as required.
DFO briefings involving the FCO, FEMA staff and all ESFs in the DFO as well as
special staff are held twice daily. These usually coincide with the shift change.
Overall control authority for all ESF #10 operaticns in the RRC, the DFO and the
OSC Field Teams is the ESF #10 Chair or designee. If a designee is required, the
ESF #10 Chair will designate this person in writing and provide copies to the DFO
and MCP.
DFO operations will be under the command and control of the designated DFO
Team Chief.
As discussed in TAB F, the designated Incident OSC exercises command and
control over all tactical field operations involving ESF #10 personnel. It is
necessary for the IOSC to maintain continued contact with the DFO to provide
real-time status of operations, site locations and situations and personnel involved.
The DFO Team uses this information to provide input to the daily briefings and to
July 18, 1995
•"COORDINATION DRAFT"* ESF #10-3-15
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other ESFs as necessary. In turn, the DFO may acquire information needed by
the IOSC.
Upon the establishment of the DFO for a catastrophic disaster that involves
discharges of oil in the coastal zone, USCG representation at the DFO will be
determined on a case by case basis between the appropriate USCG District and
the ESF #10 Chair. This same arrangement will apply in situations involving
DOD or DOE.
July 18, 1995
"•COORDINATION DRAFT***
ESF #10-3-16
-------
TAB E: ESP #10 Commaod & Control, to Appendix 3, Operations
INTRODUCTION:
The Regional Response Center (RRC) is located in the EPA Regional Office,
and is the coordination, communications and control center for all ESF #10
operations. All ESF #10 activities in the ROC, the ERT-A, the DFO and in the
field are coordinated through the RRC. The ESF #10 Chair is normally located in
and operates from the RRC. The RRC has conference spaces that may be used by
the Regional Response Team, the EPA Regional Incident Coordination Team or
other organizations. When the situation requires a USCG response, the USCG
ESF #10 Vice-Chair would establish a separate operations center and a
communications link between these response centers will be established and
maintained.
Initial Response Actions:
Upon arrival at the Regional Response Center, the RRC staff will focus initially on
the following actions:
1. Confirm alert and notification of available OSCs and issue deployment
instructions as ordered.
2. Establish communications with the ROC.
3. Confirm deployment or deploy ERT-A staff.
4. Establish contact and alert members of the Regional Incident
Coordination Team (RICT).
5. Establish contact with EPA Headquarters EOC.
CONTINUING DISASTER OPERATIONS:
Following activation of the RRP, the functions and structures created to manage
the Federal response transition through a series of changes to arrive at a
DFO/FCO function that continues until the elements of the ERT are deactivated.
These events begin with the activation of the ROC, the deployment of the ERT-A
and the FAsT Teams and continue through a phase-out of these functions and the
establishment of field operations and a DFO. These processes are illustrated in
figures 5, 6 and 7,
Figure 5 shows the ESF #10 initial deployment. For an impending hurricane,
these functions may be deployed beginning 24 hours before landfall and will
July 18,1995
"•COORDINATION DRAFT*** ESF #10-3-17
02 72
-------
continue through the first 48 to 72 hours after landfall. In a flood situation, the
same pre-event deployment may take place and the follow on transitions would
occur during the same time frame while the flooding may be continuing. A no-
notice event such as an earthquake will produce the same structures, but the time
to transition may be reduced.
Figure 6 illustrates the transition to field operations. The RRC continues in full
operation, supported by the Regional Response Team and the Regional Incident
Coordination Team, the ROC and ERT-A transition into the DFO and the FAsT
Team personnel, support and equipment transition into the OSC Field Team.
Figure 7 shows the operational field deployment and the interrelationships among
the various ESF #10 components. Once this structure has stabilized and
operations begin, several options for Command and Control of ESF #10 are
possible. Three are described in the following section.
COMMAND AND CONTROL:
Command and Control (C&C) concepts during a FRP/ESF #10 activation and
response differ from normal ERRB operations. Hie impact of a disaster is usually
widespread and with a multitude of emergency situations occurring
simultaneously. Distances between locations where oil and hazardous substances
occur may be great and a large number of OSCs and contractor personnel will be
deployed. The availability of traditional responses from local government and
other emergency first responders may be limited or not available because of direct
disaster impact or other priority commitments.
Three C&C options are included in this TAB. These may be used as described or
modified by the ESF #10 Chair to fit the situation. These options are guides only
and will be modified as necessary to fit the situation. Each of these options is
described below and illustrated in figures 8, 9, and 10.
C&C OPTION ALPHA:
This option (figure 8) centers all strategic planning and overall operational control
in the Regional Response Center. Branch management exercises overall C&C and
oversees the strategic planning. Specific operations are controlled from the RRC
by the Assessment Team Leader, Household Hazardous Waste Team Leader and
Support Team Leaders representing each EPA Regional Division/Office committed
in a support role.
Field operations are coordinated through the Mobile Command Post which serves
as the Incident Command Center. Tactical responses by OSC Teams is under the
July 18, 1995
•"COORDINATION DRAFT*** ESF #10-3-18
0273
-------
Fisi-a&L nmmm% m
REGION IV ESF #10 ACTIVATION / INITIAL DEPLOYMENT
H - 24 to H + 48/72
EPA REGION IV
ERRB
• OSCs
• Staff
Regional Incident Coordination Team
Regional Respponse Team
REGIONAL RESPONSE CENTER
EMERGENCY
RESPONSE
TEAM - A
Chief, ERRB
Chief, Emer Res Sec
RRC Coordinator
• Tel. Duty OSC
TAT
State EOC
REGIONAL OPERATIONS
CENTER (ROC)
ERRB EP Coordinator
TAT
ESF #10
EMERGENCY SUPPORT FUNCTIONS
ESFs 1- 12
FEMA REGIONAL OFFICE
FIELD
ASSESSMENT
TEAM
(FAST)
. OSCs
Jeeps
• TAT
• MCP
Chase
FEMA STAGING
V AREA
FIGURE 5. INITIAL DEPLOYMENT
0 2 7 4
-------
jr*.£
Dijm
REGION IV ESF #10 ACTIVATION
TRANSITION TO FIELD DEPLOYMENT
AND DISASTER FIELD OFFICE
H +/- 72 HOURS
REGIONAL RESPONSE
CENTER (RRC)
Chief, ERRB
Chief, Removal Ops
RRC Coordinator
Tel. Duty OSC
TAT
REGIONAL
INCIDENT
COORDINATION
TEAM
REGIONAL
RESPONSE
TEAM
DISASTER FIELD OFFICE
(DFO)
ESF #10 OPERATIONS
Chief, ERS
Emerg PC - ROC
ERT - A OSC
ERT - A TA
Figure 6. Transition
ESF #10 FIELD
OPERATIONS
10SC
FIELD TEAM
OSCs
START
MCP
JEEPS
MOTOR HOME
^-O Cf
eratic?
027 a
-------
J*
USUAL 7>Um
REGION IV ESF #10 ACTIVATION
FIELD DEPLOYMENT AND OPERATIONS
H +72 until Deactivation
REGIONAL
INCIDENT
COORDINATION
REGIONAL RESPONSE
CENTER (RRC)
Chief, ERRB
Chief, Removal Ops
RRC Coordinator
Tel. Duty OSC
START
REGIONAL
RESPONSE
TEAM
DISASTER FIELD OFFICE
(DFO)
ESF #10 OPERATIONS
Chief, ERS
Prep Coordinator-ROC
ERT-A OSC
ERT-A START
Support Liaison
ESF #10 FIELD
OPERATIONS
IOSC
FIELD TEAM
OSCs
START
Communications:
• Satellite Phone
High Fmq SSB radio
VHF radio
Cellular Phone
. nti Jne c^ne
MCP
JEEPS
MOTOR
HOME
Figure
Full
•5 » Dec*!ovT"-it
0270
-------
direction of the IOSC. Other field operations are controlled by a Field Team
Chief.
The DFO serves as a information collection, coordination and transfer point,
linking all ESF #10 and EPA support functions into the overall disaster operations
through the DFO.
Operations conducted by USCG OSCs and/or OSCs supplied by DOD or DOE are
coordinated through the RRC and information regarding their operations is also
supplied to the DFO.
C&C OPTION BRAVO:
Option BRAVO (figure 9) is designed for ESF #10 operations where the disaster
area, DFO and field elements are located geographically distant from the RRC. In
this option, overall command and control and the management of resources of the
RET and the RICT remain with the ESF #10 Chair in the RRC. The control of all
field operations is decentralized and is closer geographically to the operational
locations. The ESF #10 staff in the DFO assists the EEC in assuming more
operational control for field programs in addition to the traditional DFO
operations. Support element liaisons are also located in the DFO to link field
operations with the supported ESFs.
Tactical field response is conducted from the Mobile Command Post. The IOSC
controls all OSC teams, support from the USCG Strike Teams as appropriate and
any additional aerial reconnaissance necessary. The HHW program is directed
from the MCP by the HHW lead OSC. likewise, any EPA support operations to
other ESFs is directed by the individual support element leader.
This option is illustrated in Figure 9.
C&C OPTION DELTA
Option Delta (figure 10) farther decentralizes the operational command and
control by placing the central control in the DFO and placing all tactical control by
the IOSC, HHW OSC, the Urban Search & Rescue (ESF #9) and Firefighting (ESF
#4) Support OSC and Field Support Leaders in the MCP or other field Incident
Command Post facility. The ESF #10 Chair has the option of moving from the
RRC to the DFO, but still retains overall command and control. Strategic
planning is done mostly in the DFO. The RRC retains the direct link to EPA HQ
unless the ESF #10 Chair deploys to the DFO.
July 18, 1995
•••COORDINATION DRAFT*** ESF #10-3-19
0277
-------
EMERGENCY SUPPORT FUNCTION # 10 HAZARDOUS MATERIALS
COMMAND & CONTROL: OPTION ALPHA
REGIONAL
RESPONSE
TEAM
REGIONAL
INCIDENT
COORDINATION
TEAM
Water
REGIONAL
RESPONSE
CENTER
HOUSEHOLD HAZARDOUS
WASTE COLLECTION
ICAHCD
ASSESSMENT TEAM
LEADER
Branch Managemen
RRC Staff
DISASTER
FIELD
OFFICE
ction
&
itro
Informafbn Link
HHW FIELD
OPERATIONS
OSC
(FAsT)(AIR)
OSC
TEAM
PUBLIC INFORMATION
U0OG
STRIKE
TEAM
COLLECTION/DISPOSAL
WATER
OSC
TEAM
Figure 8, Command & Control - Cpi.cn ; h-
0278
-------
EMERGENCY SUPPORT FUNCTION # 10 HAZARDOUS MATERIALS
COMMAND & CONTROL: OPTION BRAVO
RHw
REGIONAL
INCIDENT
COORDINATION
TEAM
REGIONAL
RESPONSE
TEAM
Branch Management
RRC Staff
DJ3ASTER FIELD OFFICE
OSC / OPERATIONS
SUPPORT STAFF
HOUSEHOLD HAZARDOUS
WASTE COLLECTION
LEAD OSC
INCIDENT OSC
ASSESSMENT/RESPONSE
EPA SUPPORT 1
OPERATIONS
HHW FIELD
OPERATIONS
IOSC
(FAsT)(AIR)
OSC
TEAM
WATER
OSC
TEAM
STRIKE
TEAM
Figure 9, Command & Control, Option Bravo
ESF #10 DISASTER OPERATIONS
02 79
-------
EMERGENCY SUPPORT FUNCTION # 10 HAZARDOUS MATERIALS
COMMAND & CONTROL: OPTION DELTA
REGIONAL RESPONSE CENTER
Branch Management
RRC Staff m*
REGIONAL
INCIDENT
COORDINATION
TEAM
Water
DISASTER FIELD OFFICE
OSC/ OPERATIONS
STAFF
iSLO/MCPi
INCIDENT OSC
ASSESSMENTS
RESPONSE
Urban SAR
Firefighting
06C
ESF # 4 & 9
AIR
ESF 3/
ATER
ESF 3
DSC
,FAsT)(AIR
HHW F ELD
OPERATIONS
EPA SUPPORT
FIELD OPNS
Uroan
Search & Rescue
Team
DSC
TEAM
US Forest Service
Firefighting
LBOG
STRIKE
TEAM
Figure 10 Command & Control Option Delta
ESF #10 DISASTER OPERATIONS
0200
-------
TAB F: OSC FIELD OPERATIONS: to Appendix 3, Operation!
OSC FIELD OPERATIONS:
INTRODUCTION:
This TAB discusses operations taken during a FRP activation to assess, mitigate
or prevent harm to the health and safety of both the responders, the impacted
population, property and the environment. The response also includes clean-up
and disposal of released materials. Response operations taken under these
circumstance are under the direction of an OSC provided by the appropriate lead
Federal Agency. The operative guidance is the NCP and the RCP or appropriate
Area Contingency Plan. The numbers of incidents and demand for response assets
as a result of a disaster is expected to overwhelm local and State resources. A
number of OSCs will be in the disaster area, operating in conjunction with State
and local response personnel when available.
ANNEX A, Spill Response Organization and Command to this Plan, describes a
command structure for organizing personnel and resources for response to an oil
spill within Region IV. This structure will form the basis for an ESF #10
response.
PLANNING ASSUMPTIONS:
A catastrophic disaster event that causes severe and widespread property damage
will likely cause multiple spills of varying severity.
Spills that occur may be widely separated geographically, depending on the extent
of the disaster impact.
The sheer number of incidents occurring simultaneously will require a
prioritization of available response resources.
A Responsible Party may not be available, or may not be required or capable of
taking any response or clean-up actions.
Local emergency first responders may be overwhelmed or out of action and may
not be available to initiate public safety/initial response actions.
ORGANIZATION AND FACILITIES:
The exact field organization to be used will depend on several variables, however,
the Spill Response Unified Command Structure shown in Figure A-l of Annex A to
July 18, 1995
•"•COORDINATION DRAFT*** ESF #10-3-21
0 2 8 i
-------
the RCP will provide the basic structure. Modifications based on the planning
assumptions above or other variables and circumstances may be required.
The EPA Mobile Command Post (MCP) will be used whenever possible as the
Command & Control location for ESF #10 field response operations. The MCP
and other support vehicles as necessary provide a Base of Operations for the
response effort. ERRB response vehicles will also be used when possible by the
OSC Advance and Clean-up Teams.
CONCEPT OF OPERATIONS:
All response actions taken in the inland area and within state waters of the
coastal zone will be directly coordinated with the State and local responders
whenever possible.
The ESF #10 Chair, utilizing input from the predicted severity of an impending
disaster and/or information from the ROC, ERT-A and the affected State, will
mobilize one or more OSC Field Teams to a staging location in the vicinity of the
disaster area. These OSC Field Teams will consist of both Cleanup Teams and
Advance Teams. The specific size and composition of the teams will depend on the
actual or anticipated impact of the disaster.
As pointed out in TAB D, the FAsT Team Leader, once the Regional Field
Assessment activities have been completed, becomes the Incident OSC unless
other appointments are made by the ESF #10 Chair.
Tho fiolfl Anorafinn c /iiifiriff o rli cqofor oifii ofiATt Trmv Ko QATnoishsit rliHoranf fViot
JL JJLe? JLJLV^JLvJL |iC4 C% mU ¦ Jl O 11 lui 1SPOLP vCJfc dX JUJLGLy oviiivW*JLBlv * Mi 11* I t? 1 t v ImXcav
those under "normal" circumstances. A "Unified Command" structure may not be
possible because neither state or local responders may be available. In addition,
there may be no "Responsible Party". Thus, the ESF #10 OSC Teams may be
operating on their own. However, to the extent possible, the guidance and
procedures in Annex A should be followed.
OSC Field Team (OFT): The OFT will consist of an Incident OSC (IOSC) who is
the Team Leader and one or more OSC Advance Teams and/or Cleanup Teams.
The nucleus of this team are the ESF #10 members of the Regional FAsT Team
and the Advance Teams and TAT Support deployed to conduct the initial field
assessments. Cleanup Teams and any additional personnel and equipment
required will be mobilized as soon as information on the probable magnitude of
the event or other damage assessment information is available. Deployment of
these teams will be coordinated with the affected state counterparts. ERRB
response vehicles with radios will be used, supplemented with rental vehicles as
necessary.
July 18,1995
"~COORDINATION DRAFT*** ESF #10-3-22
02 02
-------
Incident OSC (IOSC): The IOSC is a senior OSC responsible for ensuring
immediate and effective response and is the prime coordinator and manager for all
operations. The IOSC directs the tactical operations of one or more OSC
Advance/Cleanup Teams and will be the coordination point of contact with ESF
#10 at the DFO and the RRC. If possible, the IOSC will establish or work within
an Incident/ Unified Command structure. All response activities, whether
conducted by other OSCs or response personnel, must be coordinated through the
IOSC/UCS.
Upon evaluation of the FAsT Team assessment and any subsequent assessment
actions taken by the Field Team, the Incident OSC will recommend to the ESF
#10 Chair a prioritization for response to the known events. When ever possible,
this recommendation will be a consensus with available State and local response
officials.
OSC Advance Teams: These teams are composed of an OSC and one or more
STAET personnel. They may also be augmented by other contractor personnel,
USCG Strike Teams or other trained personnel available. These teams operate
under the tactical control of the designated IOSC. In addition to the
responsibilities listed in Annex A (A-35), the Advance Teams may be tasked by the
IOSC as dictated by the situation.
Cleanup Teams: Cleanup Teams conduct containment mitigation and removal of
oil and hazardous substances releases/discharges. Cleanup Teams consist of
response contractor personnel and an OSC or State response personnel for
direction and oversight. Cleanup Teams' responsibilities are listed in Annex A (A-
44).
July 18, 1995
•••COORDINATION DRAFT***
ESF #10-3-23
0283
-------
SF # 10 HAZARDOUS MATERIALS/ENVIRONMENTAL EMERGENCIES
NATIONAL AND REGIONAL
ORGANIZATIONS
NATIONAL
National ESF #10 Chair:
Director, Chemical Emergency
Preparedness and Prevention
Office, US EPA
Catastrophic Disaster
Response Group
(CDRG)
EMERGENCY SUPPORT
TEAM (EST)
fMTQ©M^L ft
lEGIQNAL
U.S
COAST
GUARD
DISTRICT
REGIONAl 5SF # 1Q QHAIR
Chief, EPA Emergency Response
& Removal Branch
REGIONAL ESF #10 VICE-CHAIR
U.S. COAST GUARD 7th DISTRICT
Marine Safety Division
^I©D®M OW m
EPA
REGION
IV
TEA
& ©©NTR@L
Regional Incident Coord
Team (RICT)
FEMA
REGIONAL
RESPONSE
CENTER
EMERGENCY
RESPONSE TEAM
(ADVANCE)
DISTRICT
VICINITY
Figure 1. National arid Regional Organizations
||llllll!lllllll!!ll!llllllllll!lllllll
Field
Assessment
Team (FAsT)
iiiiiiiniiiiiiiimiiiiiimnHii
OSCb
TAT
IIIHIIIIIIimilllllllllllllllUIIIIIIIIUIIIIIIIIHIIIH
OSCFIELD TEAMS
Incident OSC
OSC Response Teams
Clean-up Contractors
0284
-------
Finim iii^sas! plm
REGION IV EMERGENCY SUPPORT FUNCTION # 10
(ESF #10)
ALERT/NOTIFICATION PROCEDURE
iifEHMAL
IFEMA REGION IV ilHR
JHFEMA REGION IV
EPA REGION IV
TELEPHONE DUTY OSC
(24 HR)
REGIONAL INCIDENT
COORDINATION TEAM
CHIEF. ERRB
CHIEF,
EMERGENCY RESPONSE
SECTION
RRC & ROC
STAFF
DIRECTOR,
WASTE MGT DIV
RA
DRA
CHIEF,
REMOVAL OPERATIONS
CHIEF,
REMOVAL MANAGEMENT
SECTION
OSC&
Figure 2, Alert/Notification
ESF
#10-2-3
0285
-------
FEDERAL RESPONSE PLAN)
REGION IV EMERGENCY SUPPORT FUNCTION # 10
(ESF #10)
ALERT/NOTIFICATION PROCEDURE
EXTERNAL
REGIONAL RESPONSE
CENTER
EPA HEADQUARTERS
EMERGENCY
OPERATIONS
CENTER
ESF# 10
SUPPORT
AGENCIES
REGION IV
REGIONAL
RESPONSE
TEAM
EPA BACKUP REGION
Figure 3. ESF #10 External Notification
ESF #10 2-4
02 88
-------
FEDERAL RESPONSE PLAN
REGIONAL OPERATIONS CENTER (ROC)
H - 24 TO H +72
:W
iff
r
I
ESF #1
( ESF #2
ESF #7
Operations
Support
¦lliiiilili
REGIONAL OPERATIONS CENTER (ROC)
F£MA REGIONAL OFFICE
1371 Peachtree St. N. E., Suite 700
Atlanta, GA 30309
f ESF # 6
INFORMATION
AND
PLANNING
ESF #11
Human Needs
. ESF # 3
ESF #4
A
ESF# 12
Infrastructure
\^Support
ESF #8
ESFs That EPA Supports
f « ESF #9
ESF #10
HAZARDOUS
MATERIALS
Emergency Services
Figure 4. Regional Operations Center
0287
-------
IPIPIl&L PLAM
REGION IV ESF #10 ACTIVATION / INITIAL DEPLOYMENT
H - 24 to H + 48/72
EPA REGION IV I Regional Incident Coordination Team
Regional Respponse Team
OSCs
Staff
REGIONAL RESPONSE CENTER
EMERGENCY
RESPONSE
TEAM - A
Chief, ERRB
Chief, Emer Res Sec
RRC Coordinator
• Tel. Duty OSC
TAT
State EOC
REGIONAL OPERATIONS
CENTER (ROC)
• ERRB EP Coordinator
TAT
ESF #10
EMERGENCY SUPPORT FUNCTIONS
ESFs 1- 12
FEMA REGIONAL OFFICE
FIELD
ASSESSMENT
TEAM
(FAsT)
. OSCs
Jeeps
• TAT
• MCP
Chase
FEMA STAGING
I AREA
FIGURE 5, INITIAL DEPLOYMENT
028 8
-------
?mmmL ^m^mm ¦ pilaw
REGION IV ESF #10 ACTIVATION
TRANSITION TO FIELD DEPLOYMENT
AND DISASTER FIELD OFFICE
H +/- 72 HOURS
REGIONAL RESPONSE
CENTER (RRC)
Chief, ERRB
Chief, Removal Ops
RRC Coordinator
Tel. Duty OSC
TAT
\ REGIONAL
INCIDENT
COORDINATION
TEAM
REGIONAL
RESPONSE
TEAM
S4
DISASTER FIELD OFFICE
-------
\pmmmL pmm
REGION IV ESF #10 ACTIVATION
FIELD DEPLOYMENT AND OPERATIONS
H +72 until Deactivation
REGIONAL
INCIDENT
COORDINATION
EAM
REGIONAL RESPONSE
CENTER (RRC)
Chief, ERRB
• Chief, Removal Ops
RRC Coordinator
Tel. Duty OSC
START
REGIONAL
RESPONSE
TEAM
DISASTER FIELD OFFICE
(DFO)
ESF #10 OPERATIONS
Chief, ERS
Prep Coordinator-ROC
ERT-A OSC
ERT-A START
Support Liaison
ESF #10 FIELD
OPERATIONS
IOSC
FIELD TEAM
OSCs
• START
MCP
JEEPS
MOTOR HOME
Communications:
Satellite Phone
High Freq SSB radio
VHF radio
Cellular Phone
Land Line Phone
Figure 7. Full Field Deployment
02 0 0
-------
EMERGENCY SUPPORT FUNCTION # 10 HAZARDOUS MATERIALS
COMMAND & CONTROL: OPTION ALPHA
REGIONAL
RESPONSE
TEAM
REGIONAL
INCIDENT
COORDINATION
TEAM
Water
REGIONAL
RESPONSE
CENTER
HOUSEHOLD HAZARDOUS
WASTE COLLECTION
LEADER
ASSESSMENT TEAM
LEADER
Branch Management
RRC Staff
DISASTER
FIELD
OFFICE
ction
Informalbn Link
HHW FIELD
OPERATIONS
OSC
(FAsT)(A!R)
08C
TEAM
PUBLIC INFOR
NATION
U80G
STRIKE
TEAM
COLLECTION/DISPOSAL
WATER
OSC
TEAM
DEBRIS
Figure 8, Command & Control - Option Aplha
-------
EMERGENCY SUPPORT FUNCTION # 10 HAZARDOUS MATERIALS
COMMAND & CONTROL: OPTION BRAVO
REGIONAL RESPONSE CENTER
REGIONAL
INCIDENT
COORDINATION
TEAM
REGIONAL
RESPONSE
TEAM
Branch Management
RRC Staff
DISASTER FIELD OFFICE
OSC I OPERATIONS
SUPPORT STAFF
„ , , , ,n, „
HOUSEHOLD HAZARDOUS
WASTE COLLECTION
INCIDENT OSC
ASSESSMENT/RESPONSE
EPA SUPPORT
OPERATIONS
FIELD
HHW FIELD
oec
TEAM
(FAsT)(A(R)
WATER
OSC
TEAM
STRIKE
TEAM
Figure 9, Command & Control, Option Bravo
ESF #10 DISASTER OPERATIONS
^ v 4
-------
EMERGENCY SUPPORT FUNCTION # 10 HAZARDOUS MATERIALS
COMMAND & CONTROL: OPTION DELTA
REGIONAL RESPONSE CENTER
Branch Management
RRC Staff
REGIONAL
INCIDENT
COORDINATION
TEAM
water
DISASTER FIELD OFFICE
OSC/OPERATIONS
STAFF
INCIDENT OSC
ASSESSMENTS
RESPONSE
Urban SA
Firefighting
OSC
ESF # 4 & 9
ATER
ESF 3
AIR
ESF 3/
OSC
(FAsT)(AIR
HHW FIELD
OPERATIONS
EPA SUPPORT
FIELD OPNS
Urban
Search & Rescue
Team
OSC
TEAM
US Forest Service
Firefighting
STRIKE
TEAM
Figure 10 Command & Control Option Delta
ESF #10 DISASTER OPERATIONS
029 3
------- |