Criteria for Review of Hazardous Materials Emergency Plans

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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
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Criteria for Review of Hazardous Materials Emergency Plans

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