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Introduction Wherever chemicals, fuels, or other hazardous materials are stored, processed, or consumed, there is a risk of release to the environment. In the event of a hazardous material (HAZMAT) release, it is critical that emergency responders have all the information they need to safely control the release and prevent injuries to the public or damage to the environment. For this reason, federal and state regulations require facilities that manage hazardous materials to maintain written HAZMAT Emergency Response Plans. HAZMAT Emergency Response Plans may be required by any number of federal or state agencies under different regulations. These plans may partially overlap in their requirements. A partial list of plans that might be required at an installation include:
This Fact Sheet provides a general overview of the NRT's ICP or "One Plan" guidance and discusses its applicability to Air Force installations. The documents discussed in the Fact Sheet, as well as state, local, and installation environmental authorities, should be consulted for more specific and detailed information concerning the preparation of an ICP. Applicable Policy and Guidance The applicable ICP guidance and policy for AF installations is detailed in five documents:
NRT ICP Guidance
The NRT, as well as agencies responsible for reviewing and approving federal response plans to which the ICP option applies, agree that integrated response plans prepared in the format provided in this guidance will be acceptable and are the federally preferred method of response planning. The NRT anticipates that future development of all federal regulations addressing emergency response planning will incorporate use of the ICP guidance. Also, developers of state and local requirements are encouraged to be consistent with the ICP guidance.
The ICP guidance does not change existing regulatory requirements; rather, it provides a format for organizing and presenting material currently required by the regulations. Individual regulations are often more detailed than the ICP guidance. To ensure full compliance, facility managers should continue to read and comply with all applicable federal, state and local regulations.
The sample format provided by the NRT is based on the National Interagency Incident Management System (NIIMS) Incident Command System (ICS). It dovetails with established response management practices, therefore making it more useful during an emergency. All of the elements required by the Air Force for a HAZMAT Response Plan can be incorporated into an ICP or modified ICP format.
The ICP format provided in the One-Plan guidance is organized into three main sections:
The Core Plan is intended to reflect the essential steps necessary to initiate, conduct, and terminate an emergency response action: recognition, notification, and initial response, including assessment, mobilization, and implementation. This section of the plan should be concise and easy to follow. The core plan need not detail all procedures necessary under the initial phases of a response; however, it should provide information that is time critical in the earliest stages of a response and a framework to guide responders through key steps necessary to mount an effective response. The response action section of the core plan should be convenient to use and understandable at the appropriate skill level.
The Annexes are designed to provide key supporting information for conducting emergency response actions under the core plan, as well as document compliance with regulatory requirements not addressed elsewhere in the ICP. To accomplish this, the annexes should contain sections on facility information, notification, and a detailed description of response procedures under the response management system (i.e., command, operations, planning, logistics, and finance). The annexes should also address appropriate issues related to post accident investigation, incident history, written follow-up reports, training and exercises, plan critique and modification process, prevention, and regulatory compliance.
The ICP guidance contains a series of matrices designed to assist owners and operators in the plan consolidation process and in the process of ensuring documented compliance with regulatory requirements. If a facility chooses to follow the ICP outline, these matrices can be included as Annex 8 to the facility's ICP to provide the necessary cross-reference for plan reviewers to document compliance with various regulatory requirements. The ICP can also contain linkages to facilitate integration with other emergency plans within a facility (until such plans can be fully incorporated into the ICP) and with external plans, such as Local Emergency Planning Committee (LEPC) Plans and Area Contingency Plans (ACPs).
The ICP guidance can accommodate the requirements of the Air Force installation HAZMAT Plan very easily. The relevant portions of the original Facility Response Plan and other plans can be inserted into the ICP core plan and annexes as appropriate. The site-specific contingency plans can also be incorporated in the same manner.
AFPD 32-40, AFI 32-4001, and AFI 32-4002
AFI 32-4001 outlines the responsibilities for disaster preparedness at each level of command. It requires installations to prepare a disaster preparedness operations plan (Base OPlan 32-1). Annex A of Base Oplan 32-1 covers major peacetime accidents and includes an appendix covering installation HAZMAT Emergency Response Plans.
AFI 32-4002 covers specific requirements for HAZMAT emergency planning, training, response, and reporting. This instruction requires that all installations have a HAZMAT Emergency Planning Team, charged with overseeing the installation's HAZMAT Program. AFI 32-4002 references AFMAN 32-4013 for a detailed description of the required installation HAZMAT Plan.
AFMAN 32-4013
The guide states that the purpose of the installation HAZMAT Plan is to consolidate and simplify the release prevention and response process for installation personnel. The installation HAZMAT Plan must be a usable document that is easily understood by all persons involved. It also must incorporate all compliance requirements without unnecessary reiteration. Although an ICP is not specifically required by AFMAN 32-4013, the ICP guidance should prove very useful for meeting the goal of a consolidated and simplified installation HAZMAT Plan.
AFMAN 32-4013 requires frequent review of the installation HAZMAT Plan. There are a number of triggers for reviewing and updating the plan. These include changes in permit status, installation mission or operations, requests by regulators, changes in applicable regulations or AF policy, or changes in key personnel. At a minimum, the HAZMAT Plan must be reviewed and updated every three years as required by the installation Environmental Protection Committee (EPC), and the sections related to the Emergency Planning & Community Right-to-Know Act (EPCRA) must be updated annually. Sections that are likely to change frequently should be made easily replaceable.
Attachment 3 in AFI 32-4002 provides a recommended format for a HAZMAT Plan. This outline differs from the NRT's ICP format; however, the concept of an integrated plan is the same. The HAZMAT Plan must be consistent with existing plans prepared to satisfy regulatory requirements.
Chapter 10 of AFMAN 32-4013 also provides guidance for the preparation of site-specific HAZMAT contingency plans. These plans are to be incorporated into the overall HAZMAT Plan to provide site-specific information needed by first responders to address potential releases in those areas. This information includes HAZMAT identity, evacuation procedures, immediate response actions, probable release routes, containment measures, and notification procedures.
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