Criteria for Review of Hazardous Materials Emergency Plans

NRT-1ACriteria for Review ofHazardous MaterialsEmergency PlansMay 1988NATIONAL RESPONSE TEAM

National Response Teamof the National Oil and HazardousSubstances Contingency PlanG-WER/12, 2100 2nd Street SW, Washington, DC 20593May1988NRTEnvironmentalProtectionAgencyUnited StatesCoast GuardDepartment ofCommerceDepartment ofInteriorDepartment ofAgricultureDepartment ofDefenseDepartment ofstateDepartment ofJusticeDepartment ofTransportationDepartment ofHealth andHuman ServicesFederalEmergencyManagementAgencyDepartment ofEnergyDepartment ofLaborThis document transmits the National Response Team's recommendedcriteria for reviewing emergency plans submitted to Regional ResponseTeams (RRTs) under the provisions of Section 303(g) of the EmergencyPlanning and Community Right to Know Act of 1986 ( SARA Title III).The criteria for Review of Hazardous Materials Emergency Plans are toserve as a supplement to the National Response Team's Hazardous MaterialsEmergency Planning Guide (NRT-1) published in March 1987. In additionto their use by the RRTs, the criteria also can be useful to StateEmergency Response Commissions (SERCs) and Local Emergency PlanningCommittees (LEPCs) in the development and review of plans.The National Response Team suggests the following for RRT reviews:(1) Local plans should be submitted to the RRT through the appropriateState Emergency Response Commissions (SERC) after the SERCs have completedtheir own review: (2) Regional Response Team plan review should focusprimarily on plans prepared for designated priority areas within eachState, i.e. those areas where there are concentrations of hazardoussubstances manufacturing, storage, or transportation facilities thatpose substantial hazards to the public health and safety, and shouldensure consistency between those local plans and the relevant Federalplans: and (3) Regional Response Teams should use the review and commentprocess as a form of technical assistance to SERCs and LEPCs. The reviewsdo not constitute formal approval or disapproval.For further information concerning Regional Response Team reviews,please contact:Boston, MA (I)617-860-4300New York, NY (II)and Caribbean201-548-8730Chicago, IL (V)312-353-2318Dallas, TX (VI)214-655-6444Philadelphia, PA (III) Kansas City, KS (VII)215-597-9800 913-236-3888Denver, CD (VIII)303-293-1723San Francisco, CA (IX)and the Pacific Basin Region415-974-7511Seattle, WA (X)206-442-1196Anchorage, AK907-271-5083Vice ChairmanNational Response TeamReport Oil and Chemical Spills Toll Free (800)424-8802

TABLE OF CONTENTSINTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . 1BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . 1BASIS FOR THE CRITERIA . . . . . . . . . . . . . . . . . . . 3USE OF CRITERIA . . . . . . . . . . . . . . . . . . . . . . 4RRT CONSIDERATION OF THE LEPC PLANNING PROCESS . . . . . . . 4CRITERIA FOR PLANS ..................... 6Incident Information Summary ............. 6Promulgation Document ................. 6Legal Authority and Responsibility for Response .... 7Table of Contents ................... 7Abbreviations and Definitions ............. 7Planning Factors ................... 8Concept of Operations ................. 10Instructions for Plan Use ............... 12Emergency Notification Procedures ........... 12Initial Notification of Response Agencies ....... 14Direction and Control ................. 15Communication Among Responders ............ 16Warning Systems and Emergency Public Notification ... 17Public Information and Community Relations ...... 18Resource Management .................. 19Health and Medical .................. 20Response Personnel Safety ............... 21Personal Protection of Citizens/Indoor Protection ... 22Personal Protective Measures/Evacuation Procedures . . 23Fire and Rescue .................... 25Law Enforcement .................... 26On-Going Incident Assessment ............. 26Human Services .................... 27Public Works ..................... 27Techniques for Spill Containment and Cleanup ..... 28Documentation and Investigative Follow-up ....... 29Procudures for Testing and Updating the Plan. ..... 29Training ....................... 30

CRITERIA FOR REVEIW OF HAZARDOUS MATERIALS EMERGENCY PLANSINTRODUCTIONThis document contains a set of criteria which may be used by theRegional Response Teams (RRTs) in the review of local plans underthe provisions of Section 303(g) of the Superfund Amendments andReauthorization Act of 1986 (SARA). These criteria also may beused by local emergency planning committees (LEPCs) for preparingplans as required under Section 303(a) and by state emergencyresponse commissions (SERCs) for reviewing plans as requiredunder Section 303(e) of the Act. This review guide is intendedas a companion document to the Hazardous Materials EmergencyPlanning Guide (NRT-l), and can be viewed as a supplement to theplanning process as implemented by local emergency planningcommittees.BACKGROUNDSection 303(a) of the Superfund Amendments and ReauthorizationAct of 1986 requires each local emergency planning committee toprepare comprehensive hazardous substances emergency responseplans by October, 1988. The local emergency planning committeeis required to review the plan once a year, or more frequently aschanged circumstances in the community or at any facility mayrequire.Section 303(b) requires each local emergency planning committeeto evaluate the need for resources necessary to develop,implement, and exercise the emergency plan, and to makerecommendations with respect to additional resources that may berequired and the means for providing these additional resources.Section 303(c) specifically states that "Each emergencymanagement plan shall include (but is not limited to) each of thefollowing:(1) Identification of facilities subject to therequirements of this subtitle that are within theemergency planning district, identification ofroutes likely to be used for the transportation ofsubstances on the list of extremely hazardoussubstances referred to in Section 302(a), andidentification of additional facilitiescontributing or subjected to additional risk dueto their proximity to facilities subject to therequirements of this subtitle, such as hospitalsor natural gas facilities.1

(2)(3)(4)(5)(6)(7)(8)(9)Methods and procedures to be followed by facilityowners and operators and local emergency andmedical personnel to respond to any release ofsuch substances.Designation of a community emergency coordinatorand facility emergency coordinators, who shallmake determinations necessary to implement theplan.Procedures providing reliable, effective, andtimely notification by the facility emergencycoordinators and the community emergencycoordinator to persons designated in theemergency plan, and to the public, that a releasehas occurred (consistent with the emergencynotification requirements of Section 304).Methods for determining the occurrence of arelease, and the area or population likely to beaffected by such release.A description of emergency equipment andfacilities in the community and at each facilityin the community subject to the requirements ofthis subtitle, and an identification of thepersons responsible for such equipment andfacilities.Evacuation plans, including provisions for aprecautionary evacuation and alternative trafficroutes.Training programs, including schedules fortraining of local emergency response and medicalpersonnel.Methods and schedules for exercising the emergencyplan."Under Section 303(e) of the Act, state emergency responsecommissions are required to review and make recommendations oneach plan to ensure "coordination" with the plans of other localemergency planning districts.Under Section 303(g) of the Act, the Regional Response Teams "mayreview and comment upon an emergency plan or other issues relatedto preparation, implementation, or exercise of such a plan uponrequest of a local emergency planning committee." This review isviewed by the National Response Team to be a form of technicalassistance to the local emergency planning committees and the2

state emergency response commissions, and is not to be consideredas an approval of these plans.Finally, under Section 303(f), the National Response Team isrequired to issue guidance documents for the preparation andimplementation of emergency plans. In March, 1987 the NationalResponse Team published and distributed the first such guidancedocument by issuing NRT-1, the Hazardous Materials EmergencyPlanning Guide. NRT-1 contains extensive discussion of both theplanning process and the elements or contents required for aneffective hazardous materials emergency response plan. Thefollowing plan review criteria are issued as supplementaltechnical guidance to NRT-1.BASIS FOR THE CRITERIAThe review criteria are based on the guidelines for plans ascontained in Section 303(c) of the Act, NRT-1, and CPG l-8, Guidefor Development of State and Local Emergency Onerations Plans,published by the Federal Emergency Management Agency. Section303(c) outlines the minimum requirements for local emergencyresponse plans. The criteria which address these minimumrequirements are introduced throughout the document by thephrase "the plan shall." The criteria based upon NRT-1, whichexpand upon the above minimum requirements, include all theelements that the NRT considers essential for an effectivehazardous materials emergency response plan. While localemergency planning committee plans are not required to containall these elements, the NRT believes that they should.Accordingly, the criteria based on the planning elements in NRT-1(and many of the elements in CPG l-8) are introduced by thephrase "the plan should." In those cases where a plan may beimproved by including other considerations, the criteria areintroduced by the phrase "the plan might." In these cases, thecriteria are not recommended either by Title III, NRT-1, or CPGl-8.There also are criteria included in this document that areconsidered to be of such merit that they are placed under thecategory "the plan should", but cannot be specifically cited fromTitle III, NRT-1, or CPG 1-8.subsequent revisions to NRT-1 anddocument with an asterisk (*).These criteria will be included inare highlighted in thisCPG l-8 (used as one of the sources for these criteria) is usedby local governments to develop emergency operations plans whichare required by the Comprehensive Cooperative Agreements betweenthe Federal Emergency Management Agency and the states. CPG l-8a Guide for the Review of State and Local Emergency OperationsPlans, also was used as a resource for developing these reviewcriteria. The planning elements in CPG l-8 have been3

incorporated into NRT-1, and most of the review criteria in CPGl-8a are included in the attached RRT Plan Review Document. Therelevant sections of Title III, NRT-1, and CPG l-8 are indexed inthe review document for informational purposes.The plan criteria outlined below are structured to correspond tothe sequence of plan elements suggested by Chapters 4 through 6of NRT-1 and Chapters 2 and 3 of CPG l-8.USE OF CRITERIAThe NRT expects that the primary use of these criteria will be inplan review by Regional Response Teams. Through the use of thesecriteria and the development of comments related thereto, theRRTs can both conduct organized and systematic reviews of localplans and ensure that plan elements of particular interest toRRTs are covered. The RRTs should also use the criteria as abasis for ensuring coordination between federal plans developedunder the National Contingency Plan (e.g., Regional ContingencyPlans and OSC Plans) and plans developed at the local level.As mentioned above, the local emergency planning committees mayfind the criteria useful in the development of plans requiredunder Section 303(c) of the Act. These criteria are concisestatements of the contents of plan elements covered in NRT-1 andCPG l-8, and all of the plan elements required in Section 303(c).It is essential, however, that the criteria be used by localemergency planning committees only in concert with the full rangeof available guidance.State emergency response commissions may find the plan criteriauseful in the coordination of local emergency planning committeesand in the review of each local plan. The criteria offer a usefulguide for all of the planning elements which may requirecoordinated and consistent treatment among the local emergencyplanning committees within a state. They also provide the basisfor a more general review of plans.RRT CONSIDERATION OF THE LEPC PLANNING PROCESSOne of the major themes of NRT-1 is that the way in which a localhazardous materials emergency plan is developed is as importantas the actual contents of such a plan. Thus, the RegionalResponse Teams may find it useful to secure the followinginformation pertaining to the local emergency planning committeeunder review:1. A list of the names and affiliations of the members of theLEPC;4

2. A description of the activities and accomplishments (withcompletion dates) of the committee in compliance withSection 301, including:Appointment of a chairperson;Establishment of rules for committee operations;Development of methods for public notification ofcommittee activities:Conduct of public meetings on the emergency plan;Receiving and responding to public comments: andPublic notice of availability of emergency responseplan, Material Safety Data Sheets, and inventory formsunder Section 324;Dealing with public requests for information underSections 311, 312 and 313; andSecuringplan.information from facilities covered by the3. A description of the major activities of the committee incompleting the tasks for the hazard analysis and capabilityassessment.4. A summary of the data produced by these tasks, if notalready described in the plan.5. A summary of the resources expended in developing the plan,including local funds, staff effort and technical expertise,plus a summary of resources required for maintaining andrevising the plan.6. A description of any findings on ways to fund hazardousmaterials emergency planning within the district.5

CRITERIA FOR PLANS1.0 INCIDENT INFORMATION SUMMARYThe Plan shoud lcontain:1.1 Detailed description of the essentialinformation that is to be developedand recorded by the localresponse system in an actual incident,e.g., date, time, location,type of release, and material re-leased;DOCUMENTATIONTITLE III NRT-1 CPG l-8A.12.0 PROMULGATION DOCUMENTThe Plan should contain:2.1 A document signed by the chairpersonof the LEPC, promulgating the planfor the district;2.2 Documents signed by the chief executivesof all local jurisdictionswithin the district 2 ; andA.2 2.3(a) (1)*1. (a) All criteria with a Title III reference are requested by section303(c) of the Act and are introduced by the phrase "The Plan shall."(b) All criteria with an NRT-1 reference are not required by TitleIII, but are regarded as essential by the NRT for an effective hazardousmaterials emergency response plan. They can be found in NRT-1, Chapter 5,"Planning Elements", and are introduced by the phrase "The Plan should."(c) All CPG l-8 references include those criteria that address requirementsfor emergency operations plans prepared under the provisions ofthe Comprehensive Cooperative Agreements with the Federal Emergency ManagementAgency.2 These criteria are considered to be of such merit that they areincluded under the heading The plan should", but cannot specifically becited from Title III, NRT-1, or CPG l-8. They are designated in thedocumentation section by an asterisk (*). They will be included insubsequent revisions to NRT-1.6

CRITERIA FOR PLANS2.3 Letters from affected facilities endorsingthe plan.The Plan might contain:2.4 Letters of agreement between theaffected facilities and local jurisdictionsfor emergency response andnotification responsibilities.DOCUMENTATIONTITLE III NRT-1 CPG l-8*A.23.0 LEGAL AUTHORITY AND RESPONSIBILITYFOR RESPONSEThe Plan should:3.1 Describe, reference, or includelegal authorities of the jurisdictionswhose emergency response rolesare described in the plan, includingauthorities of the emergency planningdistrict and the local jurisdictionswithin the district; and3.2 List all other authorities the LEFCregards essential for responsewithin the district, including stateand federal authorities.A.3 2.3(h)II4. TABLE OF CONTENTSThe Plan should:4.1 List all elements of the plan, providetabs for each and provide across-reference for all of the ninerequired elements in Section 303 ofthe Act. Plans that are prepared inthe context of requirements of CPGl-8 should contain an index to thelocation of both NRT-1 and Section303 elements.A.4 2.3(a) (3)5. ABBREVIATIONS AND DEFINITIONSThe Plan should:7

CRITERIA FOR PLANSDOCUMENTATIONTITLE III NRT-1 CPG l-85.1 Explain all abbreviations and defineall essential terms included in theplan text.A.5 2.3(i)6.0 PLANNING FACTORSAssumption: Assumptions are theadvance judgments concerning whatmight happen in the case of an accidentalspill or release.The Plan should:6.1 List all of the assumptions aboutconditions that might develop in thedistrict in the event of accidentsfrom any of the affect& facilitiesor along any of the transportationroutes.Planning FactorsThe planning factors consist of allthe local conditions that make anemergency plan necessary.The Plan shall:6.2 Identify and describe the facilitiesin the district that possess extremelyhazardous substances and thetransportation routes along whichsuch substances may move within thedistrict:6.3 Identify and describe other facilitiesthat my contribute to additionalrisk by virtue of their proximityto the above mentioned facilities:6.4 Identify and describe additionalfacilities included in the plan thatare subject to additional risks dueto their proximity to facilitiesA.6 2.3(c)303(c) (1) A.6 2.3(c)IIII8

CRITERIA FOR PLANSDOCUMENTATIONTITLE III NRT-1 CPG l-8with extremely hazardous substances;and6.5 Include methods for determining thata release of extremely hazardoussubstances has occurred, and thearea of population likely to be affectedby such release.The Plan should:6.6 Include the major findings from thehazard analysis, (date of analysisshould be provided) which shouldconsist of:6.6.1 Major characteristics of affectedfacilities/trasportationroutes impacting on thetypes and levels of hazardsposed, including the types,identities, characteristics,and quantities of hazardousmaterials related to facilitiesand transportation routes;6.6.2 Potential release situationswith possible consequences beyondthe boundaries of facilities,or adjacent to transportationmutes. Use may be madeof historical data on spillsand any data on spills and anydata secured from facilitiesunder Section 303(d)(3) of theAct;6.6.3 Maps showing locations of facilities,transportation routes,and special features ofdistrict, including vulnerableareas;6.7 Geographical features of the district,including sensitive environmentalareas, land use patterns,water supplies, and public transportation;9303(c) (5) A.62.3(c)A.6 2.3(a) (4)

CRITERIA FOR PLANSDOCUMENTATIONTITLE III NRT-1 CFG l-86.8 Major demographic features of thedistrict, including those featuresthat impact most on emergency responsee.g., population densityspecial populations, and particularlysensitive institutions;6.9 The district's climate and weatheras they affect airborne distributionof chemicals; and6.10 Critical time variables impacting onemergencies, e.g., time of day andmonth of year in which they wouldbe most likely occur.A.6 2.3(a) (4)7.0 CONCEPT OF OPERATIONSThe Plan shall:7.1 Designate a emergency co- 303(c) (3)ordinator and facility emergencycoordinators, who shall make determinationsnecessary to implement theplan.The Plan should:7.2 Identify, by title, the individualdesignated as the community emergencycoordinator and each of the facilityemergency coordinators;7.37.4Explain the relationships betweenthese coordinators, their organizations,and the other local governmentalresponse authorities withinthe district, e.g., the county emergencymanagement authority;Describe the relationship betweenthis plan and other response planswithin the district which deal inwhole or in part with hazardousmaterials emergency response, e.g.the county Emergency Operations Plan10A.7bA.7c2.3(d)

CRITERIA FOR PLANSDOCUMENTATIONTITLE III NRT-1 CPG 1-8and plans developed by fire departmentsunder OSHA Regulation CFR 29Part 1910-120;7.5 List all the facility emergencyplans within the district that applyto hazardous materials emergency response,including all plans developedunder OSHA Regulation on HazardousWaste Operations and EmergencyResponse (CFR 29 CFR Part 1910.120);7.6 Describe the way in which the aboveplans are integrated with local responseplans:7.7 Describe the functions and responsibilitiesof all the local responseorganizations within the district,including public and private sectoras well as volunteer and charitableorganizations;7.8 List mutual aid agreement or otherarrangements for sharing data andresponse;7.9 Describe conditions tier which thelocal government will coordinate itsresponse with other districts andthe means or sequence of activitiesto be followed by districts in interactingwith other districts;7.10 Describe the relationship betweenplans of the district and relatedstate plans;7.11 Describe the relationship betweenlocal and state emergency responseauthorities: and7.12 Describe the relationships betweenemergency response plans and activitiesin the district and responseplans and activities by federalagencies, including all plans andA.7cA.7bA.3A.7bA.7cA.7bA.7b;A.7c2.3 (e)11

CRITERIA FOR PLANSDOCUMENTATIONTITLE III NRT-1 CPG l-8responses outlined in the NationalContingency Plan.[Emphasis should be given to theallocation of responsibilities amongfederal emergency response agencies,including listing the names and theresponsibilities of federal responseagencies and entities such as theRRT, describing the means for theirnotification, the types of resourcesto be sought from them, the mansfor obtaining them, the conditionsunder which assistance is to be provided,and the methods of coordinationduring a response]8. INSTRUCTIONS FOR PLAN USEThe Plan should:8.1 Contain a discussion of the purposeof the plan; and8.2 Contain a list of organizations andpersons receiving the plan or planamendments and the date that theplan was transmitted as well as aspecific identification number foreach plan.A.8aA.8b2.3(a) (5) (b)2.3(a) (5) (c)9.09.1RECORD OF AMENDMENTSThe Plan should:Contain a section that describesmethods for maintaining and revisingthe plan and recording all changesin the plan, including a method forcontrolling distribution.A.9 2.3 (a) (6)10.0 EMERGENCY NOTIFICATION PROCEDURESThe Plan shall:12

CRITERIA FOR PLANSDOCUMENTATIONTITLE III NRT-1 CPG l-810.1 Include procedures for providingreliable, effective, and timely notificationby the facility emergencycoordinators and the community emergencycoordinator to persons designatedin the emergency plan, and tothe public, that a release has303(c)(4) c.43.3(c)The Plan should:10.2 Include procedures for immediatelynotifying the appropriate 24-hourhotline first, and should locatetheseprocedures in a prominentplace in the plan:10.3 List the 24-hour emergency hotlinenumber(s) for the local emergencyresponse organization(s) within thedistrict;10.4 Contain an accurate and up to dateEmergency Assistance Telephone Rosterthat includes numbers for the:10.4.1 Technical and response personnel;10.4.2 Community emergency coordinator,and all facility emergencycoordinators;10.4.3 CHEMTREC;10.4.4 National Response Center; 310.4.5 Other participating agencies:10.4.6 Community emergency coordinatorsin neighboring emergencyplanning districts;C.lB*3 Spills exceeding the CERCLA reportable quantities are requiredto be reported to the National Response Center.13

CRITERIA FOR PLANS10.4.7 Public and private sector supportgroups; and the10.4.8 Points of contact for all majorcarriers on transportation routeswithin the district;10.5 List all local organizations to benotified of a release, and the orderof their notification, and listnames and telephone numbers of primanyand alternate points of contact:10.6 List all local institutions to benotified of the occurrence of a releaseand the order of their notification,and the names and telephonenumbersof contacts;10.7 List all state organizations to benotified, and list the names andtelephone numbers of contacts: and10.8 List all federal response organizationsto be notified, and the namesand telephones nmbers of the contacts.DOCUMENTATIONTITLE III NRT-1 CFG l-8B***11.0 INITIAL NOTIFICATION OF RESPONSEAGENCYThe plan should:11.1 Describe methods or means to be usedby facility emergency coordinators(FECs) within the district to notifycommunity emergency coordinators(CECs) of any potentially affecteddistricts, and SERCs of any potentiallyaffected states, and myother persons to whom the facilityis to give notification of any releastin compliance with Section304 of Title III;11.2 Describe methods by which the CECsand local response organizations14C.l

CRITERIA FOR PLANSDOCUMENTATIONTITLE III NRT-1 CPG 1-8will be notified of releases fromtransportation accidents, followingnotification through 911 system orspecified alternative means:11.3 Describe methods by which the CEC,or his designated agent, will ensurethat contents of notification matchthe requirements of Section 304,including the regulations containedin 40 CFR Part 355 (Notification Requirments,Final Rule);11.4 List procedures by which the CECwill assure that both the immediateand follow-on notifications fromfacility operators are made withinthe time frames specified by Notificationof Final Rule in 40 CFRPart 355; and11.5 Identify the person or office responsiblefor receiving the notificationfor the community emergencycoordinator or his/her designatedagent and list the telephone number;C.112.0 DIRECTION AND CONTROLThe Plan shall:12.1 Include methods and procedures to befollowed by facility owners and operatorsand local emergency and medicalpersonnel to respond to areleaseof extremely hazardous substances.303 (c) (2)The Plan should:12.2 Identify the organization within thedistrict responsible for providingdirection and control to the overallemergency response system describedin the Concept of operations;C.2 3.3(a)15

CRITERIA FOR PLANS12.3 Identify persons or offices withineach response organization who providedirection and control to eachof the organizations;DOCUMENTATIONTITLE III NRT-1 CPG l-8C.2 3.3(a)12.4 Identify persons or offices providingdirection and control withineach of the emergency response function;12.5 Describe persons or offices responsiblefor the performance of incidentcommand functions and the wayin which the incident command systemis used in hazardous substancesincidents:12.6 Describe the chain of command forthe total response system, for eachof the major response functions andfor the organization controlled bythe incident commander; and12.7 Identify persons responsible forthe activation and operations of theemergency operations center, the onscenecommand post, and the methodsby which they will coordinate theiractivities:12.8 List three levels of incident severityand associated response levels;12.9 Identify the conditions for eachlevel: and12.10 Indicate the responsible organizationsat each level.13.0 COMMUNICATION AMONG RESPONDERSThe Plan should:13.1 Describe all the methods by whichidentified responders will exchangeinformation and communicate witheach other during a response, in-C.3 3.3(b)16

CRITERIA FOR PLANSDOCUMENTATIONTITLE III NRT-1 CPG l-8cluding the commmications networksand common frequencies to be used;[At a minimum, these methods shouldbe described for each function. Bothcommunications among local responseunits and between these units andfacilities where incidents occurshould be described]13.2 Describe the methods by which emergencyresponders can receive informationon chemical and relatedresponse measure; and[May include a description of computersystems with on line databases]13.3 Describe primary and back-up systemfor all comunication channels andsystems.The Plan might:13.4 contain a diagram or matrix showingthe flaws of information within theresponse system.C.3* 3.3(b)14.0 WARNING SYSTEM AND EMERGENCY PUBLICNOTIFICATIONThe Plan should:14.1 Identify responsible officials withinthe district and describe themethods by which they will notifythe public of a release from anyfacility or along any transportationroute, including sirens or othersignals, and use of the broadcastmedia and the Emergency BroadcastSystem. This should include a descriptionof:14.1.1 The sirens and other signals tobe employed, their meaning,their methods of coordination,17C.4 3.3(c)

CRITERIA FOR PLANSand their geographical coverage:14.1.2 Other methods, such as door-todooralerting, that my beenployed to reach segments ofthe population that may not bereached by sirens or other signals:and14.1.3 Time frames within which notificationto the public can beaccomplished;14.2 Describe methods for the coordinationof emergency public notificationduring a response; and14.3 Describe any responsibilities oractivities of facilities covered bythe Act for emergency public notificationduring a response.DOCUMENTATIONTITLE III NRT-1 CPG l-8C.4 3.3(c)15. PUBLIC INFORMATION AND COMMUNITYRELATIONSThe Plan should:15.l Describe the methods used by localgovernments, prior to emergencies,for educating the public about possibleemergencies and planned protectivemeasures;15.2 Describe the role and organizationalposition of the public informationofficer during emergencies;15.3 Designate a spokesperson and describethe methods for keeping thepublic informed during an emergencysituation, including a list of allradio, TV, and press contacts; and15.4 Describe any related public informationactivities of affected faci-C.5 3.3(d)*18

CRITERIA FOR PLANSDOCUMENTATIONTITLE III NRT-1 CPG 1-8lities, both prior to an emergencyand during an emergency.16.0 RESOURCE MANAGEMENTThe Plan shall:16.1 Include a description of emergencyequipment and facilities in the communityand at each facility in thecommunity subject to the requirementsof this subtitle and an identificationof the persons responsiblefor such equipment and facilities.303(c) (6)The Plan should:16.2 List personnel resources availablefor emergency response by major categories,including governmental,volunteer, and the private sector;16.3 Describe the types, quantities, capabilitiesand locations of emergencyresponse equipment available to thelocal emergency response units, includingfire, police and emergencymedical response units.[Categories of equipment should includetransportation, communications,monitoring and detection,containment decontamination, removal,and cleanup]16.4 List the emergency response quipmentavailable to each of the affectedfacilities and describe themin the same way as community equipmentis described;16.5 Describe the emergency operatingcenters or other facilities availableto the local community and thefacility emergency coordinators andother response coordinators, such asincident commanders;C.6 3.3(n)19

CRITERIA FOR PLANSDOCUMENTATIONTITLE III NRT-1 CPG l-816.6 Describe emergency response equipmentand facilities available toeach affected facility and the conditionsunder which the are to beuse support of local reponders;16.7 Describe significant resource shortfallsand mutual support agreementswith other jurisdictions where by thedistrict might increase its capabilitiesin an emergency;[This my be discussedConcept of Operations]under the16.8 Describe procedures for securingassistance from federal and stateagencies and their emergency supportcontractors;[This may be discussed under theConcept of Operations]16.9 Describe emergency response capabilitiesand the expertise in theprivate sector that might be availableto assist local responders,facility managers, and transportationcompanies during emergencies.C.6 3.3(n)II17.0 HEALTH AND MEDICALThe Plan shall:17.1Include methods and procedures to befollowed by facility owners and operatorsand local emergency and medicalpersonnel to respond to a releaseof extremely hazardous substances.The Plan should:17.2 Describe the procedures for summoningemergency medical and healthdepartment personnel;20303(c) (2)C.7 3.3(h)

CRITERIA FOR PLANSDOCUMENTATIONTITLE III NRT-1 CPG l-817.317.517.617.717.817.9Describe the procedures for themajor types of emergency medicalservices, including first aid, triage,ambulance service, and emergencymedical care, using both theresources available within the districtand those that can be securedin neighboring districts;17.4 Describe the procedures to be followedfor decontamination of exposedpeople:Describe the procedures for providingsanitation, food, water supplies,and safe re-entry of personsto the accident area;Describe procedures for conductinghealth assessments upon which tobase protective action decisions;Describe the level and types ofemergency medical capabilities inthe district to deal with exposureof people to extremely hazardoussubstances;Describe the provisions for emergencymental health care; andIndicate mutual aid agreement withother communities to provide backupemergency medical and health departmentpersonnel, and equipment.C.7 3.3(h)*C.718.018.1RESPONSE PERSONNEL SAFETYThe Plan should:Describe initial and follow-up proceduresfor entering and leavingincident sites, including personnelaccount ability personnel safety precautions,and medical monitoring:21C.8

CRITERIA FOR PLANS18.2 Describe personnel and equipmentdecontamination procedures; andDOCUMENTATIONTITLE III NRT-1 CPG l-8C.818.3 List sampling, monitoring and personnelprotective equipment appropriateto various degrees of hazardsbased on EPA levels of protection(A, B, C, & D).[Just prior to publication of NRT-1,the Occupational Safety and HealthAdministration (OSHA) published proposedrules (29 CFR Fart 1910.120)to provide more definitive requirementsto plan for emergency responsepersonnel safety. If the LEPC plansinclude a section on this function,the plan elements listed in the OHSAregulation should be used]19.0PERSONAL PROTECTION OF CITIZENS/IN-DOOR PROTECTIONThe Plan shall:19.1Describe methods in place in thecommunity and in each of the affectedfacilities for determining theareas likely to be affected by arelease.303(c) (5)The Plan should:19.2Include methods to predict the speed,direction, and concentration ofplumes resulting from airborne releases,and methods for modelingvapor cloud dispersion as well asmethods to monitor the release andconcentrations in realtime:C.9a3.3(g)[19.1 and 19.2 may be considered inthe hazard analysis, included inSection 6, Planning Factors]19.3 Identify the decision making pro-22

CRITERIA FOR PLANSDOCUMENTATIONTITLE III NRT-1 CPG 1-8cess, including the decision makingauthority for indoor protection:19.4 Describe the roles and activities ofaffected facilities in the decisionmaking for indoor protection decisions,including the determinationthat indoor sheltering is no longerrequired:19.5 Indicate the conditions under whichindoor protection would be recommended,including the decision makingcriteria;19.6 Describe the methods for indoor protectionthat would be recommendedfor citizens, including provisionsfor shutting off ventilation systems;and19.7 Describe the methods for educatingthe public on indoor protective masures;[May be discussed in the section onpublic information]C.9aC.9a3.3 (g)20.0 PERSONAL PROTECTIVE MEASURES / EVAC-UATION PROCEDURESThe Plan shall:20.1 Describe evacuation plans, includingthose for precautionary evacuationsand alternative traffic routes;The Plan should:20.2 Describe the authority for orderingor recommending evacuation, includingthe personnel authorized torecommend evacuation:20.3 Describe the authority and responsibilityof various governmentalagencies and supporting private sec-23303(c) (7) C.9b 3.3(e)

CRITERIA FOR PLANStor organizations, such as the RedCross, and the chain of commandamong them;20.4 Describe the role of the affectedfacilities in the evacuation decision-making:20.5 Describe methods to be used in evacuation,including methods for assistirgthe movement of mobilityimpaired persons and in the evacuationof schools, hospitals, prisonsand other facilities;20.6 Describe the relationship of evacuationprocedures to other protectivemeasures.20.7 Describe potential conditions requiringevacuation, i.e., the typesof accidental releases and spillsthat may require evacuation:20.8 Describe evacuation routes, includingprimary and alternative routes;[These may be either establishedroutes for the community or specialroutes appropriate to the locationof facilities]20.9 Describe evacuation zones and distancesand the basis for their determination;[These should be related to the locationof facilities and transportationroutes and the potential pathwaysof exposure]20.10 Describe procedures for precautionaryevacuations of special populations;20.11 List the mass care facilities forproviding food, shelter and medicalcare to relocated populations;24DOCUMENTATIONTITLE III NRT-1 CPG l-8*C.9b*C.9b" 3.3(e)II

CRITERIA FOR PLANSDOCUMENTATIONTITLE III NRT-1 CPG l-8[This may be discussed under thehuman services section]20.12 Describe procedures for providingsecurity for the evacuation, forevacuees and of the evacuated areas;[May be covered under the law enforcementdiscussions]20.13 Describe methods for managing theflow of traffic along evacuationroutes and for keeping the generalpublic from entering threatened areas,including maps with traffic andother control points; and[May be covered in the law enforcementsection]20.14 Describe the procedures for managingan orderly return of people to theevacuated area;C.11 3.3(i)C.9b3.3 (e)21.0 FIRE AND RESCUEThe Plan should:21.1 List the major tasks to be performedby firefighters in copingwith releases of extremely hazardoussubstances;C.10 3.3(k)21.2 Identify the public and private sectorfire protection organizationswith a response capability and responsibilityfor hazardous materialsincidents;21.3 Describe the command structure ofmulti-agency, multi-jurisdictionalincident management systems inplace, and identify applicable mutualaid agreements and Good Samaritanprovisions in place;25

CRITERIA FOR PLANS21.4 List available support systems, e.g.protective equipment and emergencyresponse guides, DOT Emergency ResponseGuidebook, mutual aid agreements,and good samaritan provisions;and[May be covered under resource management]21.5 List and describe any HAZMAT teamsin the district.[May be covered in Section 21.2above]DOCUMENTATIONTITLE III NRT-1 CPG l-8C.10 3.3(k)*22.0 LAW ENFORCEMENTThe Plan should:22.1 Describe the command structure ofmulti-agency, multi-jurisdictionalincident management systems inplace, and identify applicable mutualaid agreements and Good Samaritanprovisions in place:22.2 List the major law enforcementtasks related to respondingto releasesof extremely hazardous materials,including those related to securityfor the accident site and forevacuation activities; and22.3 List the locations of control pointsfor the performance of tasks, withappropriate maps.C.11 3.3(i)*23.0 ON-GOING INCIDENT ASSESSMENTThe Plan should:23.1 Describe methods in place in thecommunity and/or each of the affectedfacilities for determining theC.12 3.3(p)26

CRITERIA FOR PLANSareas likely to be affected by anongoing release.23.2 Describe methods for determining theprivate and public property that maybe in the affected areas and thenature of the impact of the releaseon this property;23.3 Describe methods and capabilities ofboth local response organizationsand facilities for monitoring thesize, concentration, and migrationof leaks, spills, and releases, includingsampling around the site:and23.4 Describe provisions for enviromentalassessments, biological monitoring,and contamination surveys;DOCUMENTATIONTITLE III NRT-1 CPG l-8C.12 3.3(p)24.0 HUMAN SERVICESThe Plan should:24.1 List the agencies responsible forproviding emergency human services,e.g., food, shelter, clothing, continuityof medical care, and crisiscounseling; andC.13 3.3(m)24.2 Describe the major human servicesactivities and the means for theiraccomplishment.25. PUBLIC WORKSThe Plan should:25.1 Describe the chain of command forthe performance of public works actionsin an emergency; and25.2 List all major tasks to be performedby the public works depart-27

CRITERIA FOR PLANSDOCUMENTATIONTITLE III NRT-1 CPG 1-8ment in a hazardous materials incident.26.0 TECHNIQUES FOR SPILL CONTAINMENT ANDCLEANUPThe Plan should:26.1 Explain the allocation of responsibilitiesamong local authorities andaffected facilities and responsibleparties for these activities;26.2 Describe the major containment andmitigation activities for all majortypes of HAZMAT incidents:26.3 Describe cleanup and disposal servicesto be provided by the responsibleparties and/or the local community:26.4 Describe major methods for cleanup;26.5 Describe methods to restore the surroundingenvironment, including naturalresource areas, to preemergencyconditions;26.6 Describe the provisions for longterm site control;26.7 List the location of approved disposalsites;26.8 List cleanup material and equipmentavailable within the district;[May be covered in the resourcemanagement section]26.9 Describe the capabilities of cleanuppersonne1; and26.10 List the applicable regulationsgoverning disposal of hazardousmaterials in the district.D.lD.228

CRITERIA FOR PLANSDOCUMENTATIONTITLE III NRT-1 CPG 1-827. DOCUMENTATION AND INVESTIGATIVEFOLLOW-UPThe Plan should:27.1List all reports required in thedistrict and all offices and agenciesthat are responsible for pmparingthem following a release;E27.2 Describe the methods of evaluatingresponses and identify persons responsiblefor evaluations; and27.3 Describe provisions for cost recovery.28.0 PROCEDURES FOR TESTING AND UPDATINGTHE PLANThe Plan shall:28.1 Include methods and schedules forexercising the emergency plan.The Plan should:28.2 Describe the nature of the exercisesfor testing the adequacy of theplan;28.3 List the frequency of such exercises,by type:28.4 Include an exercise schedule for thecurrent year and for future years;28.5 Describe the role of affected facilitiesor transportation companiesin these exercises; and28.6 Describe the procedues by whichperformance will be evaluated in theexercise, revisions will be made to303(c)(9) F.1F.629

CRITERIA FOR PLANSDOCUMENTATIONTITLE III NRT-1 CPG 1-8plans, and deficiencies in responsecapabilities will be corrected.29. TRAININGThe Plan shall:29.1 Include the training programs, includingschedules, for training oflocal emergency response and medicalpersonnel.The Plan should:29.2 Describe training requirements forLEPC members and all emergencyplanners within the district;29.3 Describe training requirements forall major categories of hazardousmaterials emergency response personnel,including the types ofcourses and the number of hours;29.4 List and describe the training programsto support these requirements,including all training to beprovided by the community, state andfederal agencies, and the privatesector: and29.5 Contain a schedule of training activitiesfor the current year andfor the following three years.303(c) (8) 6.4.3**30