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APPENDIX G Final Report for HMCRP Project 03 CONTENTS G-3 G.1 Introduction G-3 The Final Report Objectives G-3 Problem Statement G-3 Research Approach G-3 Literature Review G-3 Assessment Methodology G-4 Updated Phase 2 Work Plan G-4 Updated Task 8 Test Plan G-5 G.2 Literature Review G-5 Introduction G-5 Synopses of Relevant Information G-5 Established Hazardous Materials Response Guides G-6 Development of a Comprehensive Methodology G-6 Assessing Baseline Needs G-7 Assessing Capabilities G-9 Aligning Needs with Capabilities G-9 Synopses of Stakeholder Interviews G-10 Needs Assessment G-11 Capability Assessment G-12 Alignment G-12 Expert Working Group G-13 G.3 Assessment Methodology G-13 Introduction G-13 Scope G-14 Defining the Risk Metric G-15 Sources of Information G-16 Hazard Survey G-17 Methodology G-19 Risk Mitigation G-19 Emergency Response Capability Assessment G-19 Background G-20 Process G-21 Tiered Capability Assessment G-1

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G-2 A Guide for Assessing Community Emergency Response Needs and Capabilities for Hazardous Materials Releases G-22 G.4 Guide Development and Testing G-22 Introduction G-22 Draft Guide G-22 Develop Detailed Test Plan G-22 Guide Testing G-23 Selected Participants G-23 Conducting the Tests G-24 Testing Feedback G-24 Changing the Guide G-25 Attachment 1: Initial Interview Questions G-27 Attachment 2: Expert Working Group G-28 Attachment 3: Survey Questions for Guide Testers

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Final Report for HMCRP Project 03 G-3 G.1 Introduction The Final Report Objectives The objective of this project was to develop a guide for assessing community emergency response needs and capabilities for hazardous materials (hazmat) releases. This final report documents all project tasks, including those in Phase 1 already documented in the Interim Report submitted to the HMCRP Project 03 oversight panel in March 2009. This final report discusses the test of the draft Guide, including the development of the test plan, its implementation, and any issues or problems that were encountered during the test to assist future researchers to avoid them. The final report also discusses the changes made to the Guide based on the results of the test. Problem Statement The Guide addresses four elements: 1. Conducting state, regional, and local hazardous materials emergency response needs assessments; 2. Developing, maintaining, and sharing capability assessments; 3. Aligning assessed needs with various levels of capability; and 4. Identifying shortfalls where additional/different capabilities are warranted. The Guide addresses approaches for identifying and recording changes in response capability over time to allow for ongoing implementation. The Guide has been prepared, tested by planners in the field, and revised based on this feedback. Research Approach The research approach for this project was as follows. Literature Review The study team conducted a thorough literature review to identify approaches to emergency response planning and to assessing and maintaining information on local emergency response needs and capabilities. In addition, the study team conducted interviews with various stakehold- ers and experts in the field to determine the range of practices related to hazardous materials emer- gency response planning and to identify best practices. A summary of the literature review and the stakeholder interviews is presented in Section G.2 of this report. Assessment Methodology The key methodologies required for the Guide were developed in Tasks 2 through 4 and as noted above addressed: 1. Conducting state, regional, and local hazardous materials emergency response needs assessments; 2. Developing, maintaining, and sharing capability assessments; 3. Aligning assessed needs with various levels of capability; and 4. Identifying shortfalls where additional/different capabilities are warranted. The literature review and interviews conducted for this project made it clear that the most difficult task was related to hazardous materials emergency response capability assessments. The range of potential responders--from the public fire service, to facility employees, to private contractors--required a flexible approach to retain a connection to the requirements and standards that each type of responder is familiar with and under which they operate. This approach must also include an integrated view of the response capability available to a community or jurisdiction.

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G-4 A Guide for Assessing Community Emergency Response Needs and Capabilities for Hazardous Materials Releases A further challenge was to retain the concepts adopted for classifying response at the interstate and national levels, yet still address the local responders that deal with the vast majority of hazardous materials incidents. These methodologies are presented in Section G.3 of this report in an integrated format. Updated Phase 2 Work Plan The information and lessons learned from Phase 1 were used to slightly modify the approach for conducting Phase 2. The revised Phase 2 Work Plan was transmitted to HMCRP on March 31, 2009. Updated Task 8 Test Plan The knowledge gained during Phase 1 did not suggest any necessary revisions to the specific implementation of Task 8 to test the use of the Guide. The test plan is presented in Section G.4 of this report.

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Final Report for HMCRP Project 03 G-5 G.2 Literature Review Introduction The study team conducted searches for relevant literature, focusing on information related to developing a Guide for planning organizations to inventory the hazardous materials within their jurisdictions, determine the response capabilities and gaps based on their inventory, and provide guidance on how to best allocate their resources for the hazardous materials emergency response needs within their communities. As a result, a variety of sources were identified and subsequently reviewed. The remainder of this chapter describes the results of that process. Synopses of Relevant Information The discussion below contains synopses of the most important relevant literature that were obtained and reviewed. The synopses appear in no particular order. Several hazardous materials response guides have already been established, and the method- ologies and Guide being developed for this project are designed to complement them. In addition to looking at these emergency response guides, it is important to seek ways in which communities have developed (or are developing) a comprehensive methodology to build their own hazardous materials guides. This includes discussions on assessing baseline needs, assessing capabilities, and aligning needs with capabilities. Established Hazardous Materials Response Guides There are four well-known, established hazmat response guides developed by the National Response Team (NRT), Federal Emergency Management Agency (FEMA), and the Department of Health and Human Services (HHS). In addition to guides in the United States, several inter- national guidelines were also researched. The NRT's Hazardous Materials Emergency Planning Guide (NRT-1) was developed to help local communities prepare for incidents that may involve hazardous materials. It describes how to form a local planning team, find a team leader, identify and analyze hazards, identify existing response equipment and personnel, write a plan, and keep a plan up-to-date. FEMA developed the National Incident Management System (NIMS) so that responders from different jurisdictions and disciplines can work together better to respond to natural disasters and emergencies. This system provides a consistent nationwide template to enable federal, state, tribal, and local governments, the private sector, and nongovernmental organizations to work together to prepare for, prevent, respond to, recover from, and mitigate the effects of incidents regardless of cause, size, location, or complexity. Based on the interviews, it has been suggested that the emergency responders' response should be tied into NIMS, and that it should be used as a baseline template that states can build upon. FEMA has also developed the Guide for All-Hazard Emergency Operations Planning (EOP) as a state and local guide to provide emergency managers and other emergency services per- sonnel with information on FEMA's concept for developing risk-based, all-hazard emergency operations plans. This Guide clarifies the preparedness, response, and short-term recovery planning elements that warrant inclusion in state and local EOPs. It offers recommendations on how to deal with the entire planning process--from forming a planning team to writing the plan. It also encourages emergency managers to address all of the hazards that threaten their jurisdiction in a single EOP instead of relying on stand-alone plans. This Guide should help state and local emergency management organizations produce EOPs that: serve as the basis for effective response to any hazard that threatens the jurisdiction; facilitate integration

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G-6 A Guide for Assessing Community Emergency Response Needs and Capabilities for Hazardous Materials Releases of mitigation into response and recovery activities; and facilitate coordination with the federal government during catastrophic disaster situations that necessitate implementation of the Federal Response Plan. The Emergency Preparedness Resource Inventory (EPRI), which was developed by HHS, is a web-based tool for local, regional, and state planners to develop an inventory of resources in the event of a bioterrorist attack. It is a software tool that allows users to create an inventory for any region, state, or locality and can create automated reports for use in preparedness, planning, and incident response. The Emergency Response Guidebook 2008 is an international guide for use by first responders to quickly identify and respond to hazmat incidents. This guide was developed jointly by Transport Canada, the U.S. Department of Transportation, Mexico's Secretariat of Transport and Communications, and Argentina's Centro de Informacin Qumica para Emergencias. It was established to assist first responders to an emergency scene and helps to identify hazardous materials and the dangers of the hazmat. Transport Canada, which is the Canadian emergency response organization, has established guidelines for dangerous goods. In Canada, Emergency Response Assistance Plans (ERAPs) are required by the Transportation of Dangerous Goods Regulations for certain dangerous goods that require special expertise and response equipment. The plans are intended to assist local emergency responders by providing them with technical experts and specialized equipment at the accident site. Development of a Comprehensive Methodology These hazmat response guides delve into detail on how to help communities assess their baseline needs and capabilities, and to align those needs with capabilities. In addition to the information from these response guides, interviews with experts who are working with or on emergency response groups have provided valuable information on developing a response guide from the community level. They have emphasized the importance of training and equipping teams for the work that they would be doing the most and the issues they face most frequently. While an overarching response guide might be useful, it is important that needs of different communities be recognized so that they do not have to use their resources for situations that may not affect them. National Fire Protection Association (NFPA) 471, Recommended Practice for Responding to Hazardous Materials Incidents, was established to outline the minimum requirements that should be considered when dealing with hazmat incidents. This document reviews planning procedures, policies, and application of procedures for incident levels, personal protective equipment (PPE), decontamination, safety, and communications. It also indicates the importance of developing an incident response plan. Assessing Baseline Needs According to the NRT-1, a hazards analysis is a critical planning component for handling hazmat incidents. The information developed in a hazards analysis provides the basis to set priorities for planning and also the necessary documentation for supporting hazardous materials planning and response efforts. A hazards analysis may include vulnerability analysis and risk analysis, or it may simply identify the nature and location of hazards in the community. The planning team must determine the level of thoroughness that is appropriate. In any case, planners should ask local facilities whether they have already completed a facility hazards analysis. The Emergency Planning and Community Right-to-Know Act (EPCRA) requires facility owners or operators to provide to local emergency planning committees (LEPCs) information needed for the planning process. This provides guidance on how to develop the hazards analysis, including hazards identification, vulnerability analysis, and risk analysis.

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Final Report for HMCRP Project 03 G-7 The California FIRESCOPE Standardized Equipment List was established as a standardization and interoperability document for the State of California in order to describe a minimum level of standardization for first responders. The document is available for first responders to review when developing equipment specifications, purchase orders, creating or updating local master hazardous materials equipment inventory lists, and reviewing requirements for hazardous materials/weapons of mass destruction (WMD) chemical-biological response equipment grants. However, this reference document was not developed specifically for use with this Guide, and consequently, it should be used carefully. NFPA 1600, Standard on Disaster/Emergency Management and Business Continuity Programs, 2007 edition, provides a standardized basis for disaster/emergency management planning and business continuity programs. NFPA 1600 targets private and public sectors and provides common program elements, techniques, and processes for both arenas. The 2007 edition focuses on prevention, in addition to mitigation, preparedness, response, and recovery. Under the Canadian system, the development of an ERAP begins with a potential accident assessment to identify potential problems that could be encountered in the transportation cycle and determine which resources will be needed to mitigate the incident. This section must include a general analysis of how an accidental release could occur, the physical and chemical properties and characteristics of the chemical involved, a general description of the potential consequences of an accidental release, and what actions the plan holder is expected to take in case of an accident, including description of any agreements entered into with third parties to assist in remediation. Assessing Capabilities The EPRI, described in Section G.2, is a web-based tool for local, regional, and state planners to develop an inventory of resources in the event of a bioterrorist attack. The tool allows users to create an inventory for any region, state, or locality and can create automated reports for use in preparedness, planning, and incident response. Component III of NIMS encompasses resource management and includes guidance on planning, use of agreements, categorizing resources, resource identification and ordering, and the effective management of resources. This process involves accurately identifying what and how much is needed, where and when it is needed, and who will be receiving or using it. This includes equipment, facilities, and personnel and/or emergency response teams. Specific resources for critical infrastructure/key resources may need to be identified and coordinated through mutual-aid agreements and/or assistance agreements unique to those sectors, and should be accessible through preparedness organizations and/or multiagency coordination systems. The NIMS sets forth the requirement for interoperability and compatibility to enable public and private organizations to conduct well-integrated and effective incident management operations. The NIMS Supporting Technology Evaluation Program (STEP) supports NIMS implementation by providing an independent, third-party evaluation of supporting technologies to enable the use and incorporation of new and existing technologies to improve efficiency and effectiveness in all aspects of incident management. The NIMS Integration Center recognizes the need to add the capacity to recognize "Tier One" and "Tier Two" resource typing definitions. "Tier One" will continue to be national in its scope and consist of the current resource typing definitions. "Tier Two" will be those resources defined and inventoried by the states, tribal, and local juris- dictions that are specific and limited to intra-state mutual aid requests and to limited specific regional mutual aid assistance. This includes first responder resources that would not be deploy- able nationally, or are so common that national definitions are not required as they can be ordered using common language. The U.S. Coast Guard's Hazardous Materials Response Special Teams Capabilities and Contact Handbook includes a "Hazardous Materials Entry Team Typing Guidance" section. This provides

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G-8 A Guide for Assessing Community Emergency Response Needs and Capabilities for Hazardous Materials Releases specific minimum requirements for three different levels of hazmat response teams, using the following comprehensive categories: field testing, air monitoring, sampling, radiation monitoring/ detection, protective clothing, technical reference, special capabilities, intervention, decontam- ination, communications, personnel, and sustainability. The United States Fire Administration (USFA) has established the Guidelines for Response, Planning and Prevention Training for Incidents involving Hazardous Materials and Weapons of Mass Destruction (WMD) to recommend curriculum for training courses for personnel who will respond, plan for, and prevent hazmat/WMD incidents. This assists in the assessment, implementation, and development of guidelines in place at the various levels of government in the event of a hazmat or WMD incident. This document reviews the scope of personnel who need training, bridges technical differences between current editions of Occupational Safety and Health Administration (OSHA) and NFPA definitions of response competencies, and examines the training measurements and competencies. NFPA 472, Standard for Competence of Responders to Hazardous Materials/Weapons of Mass Destruction Incidents, 2008 edition, establishes a standard to identify the minimum levels of competence required by responders to emergencies involving hazardous materials/WMD. The 2008 update has changed the term "awareness level responders" to "awareness level personnel" in order to acknowledge that those first on scene may not necessarily be emergency responders. NFPA 472 covers general competencies for individuals that respond to the scene during the emergency phase, including firefighters and emergency medical technician (EMT) personnel. This covers core competencies required of emergency responders and optional mission-specific competencies. The NRT-1 capability assessment section contains sample questions to help a planning team evaluate preparedness, prevention, and response resources and capabilities. The section is divided into three parts. The first part covers questions that the planning team can ask a technical rep- resentative from a facility that may need an emergency plan. The second part includes questions related to transportation. The third part addresses questions to a variety of response and govern- ment agencies, and is designed to help identify all resources within a community. This information will provide direct input into the development of the hazardous materials emergency plan and will assist the planning team in evaluating what additional emergency response resources may be needed by the community. CHEMTREC is a 24-hour resource for obtaining immediate emergency response information for accidental chemical releases. CHEMTREC is linked to the largest network of chemical and hazardous material experts in the world, including chemicals and response specialists within the American Chemistry Council (ACC) membership, response specialists within the carrier com- munity, public emergency services, and private contractors. A useful resource is the CHEMTREC database CHEMNET, which contains a listing of support contractors with specific response capabilities. A specialist can go down the list, which provides a phone number and contact per- son for any of the companies, to determine which company best can respond to the current need. CHEMTREC will only provide the information in response to an actual emergency and is not available for centralized preplanning. However, any planning organization could individu- ally contact the organizations and develop mutual agreements for the company to meet a specific emergency response need. Under the Canadian system, the ERAP resources section should provide an up-to-date list of contacts including those in CANUTEC, Transport Canada, and contractor and technical spe- cialists that can be contacted if deemed necessary. The preparedness section should outline a comprehensive training policy aimed at providing a thorough emergency response. It should also describe the frequency of tests, at least annually, and the plans for incident and investigative

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Final Report for HMCRP Project 03 G-9 follow-up after an accident. This section should also specify the preventive maintenance needed to maintain the response equipment, tests to be performed to ensure its proper functioning, and inventory control. Maintenance records must be maintained on all emergency response equipment. The final subsections under the Preparedness section list the formal process for updating the ERAP and the required distribution list for the plan. Aligning Needs with Capabilities The National Emergency Management Association (NEMA), in coordination with the U.S. Department of Homeland Security (DHS)/FEMA and a number of emergency responders, developed a tool to assist state and local governments to prepare legislation to streamline the shar- ing of assistance and resources between communities during a disaster. The Emergency Manage- ment Assistance Compact (EMAC) is a congressionally ratified organization that provides form and structure to interstate mutual aid. Through EMAC, a disaster-impacted state can request and receive assistance from other member states quickly and efficiently. NRT-1 includes a sample outline of a hazardous materials emergency plan. This chapter presents and discusses a comprehensive list of planning elements related to hazmat incidents. Communities that are developing a hazmat plan should review these elements thoroughly. Also included in the NRT-1 is an appendix titled, "Criteria for Assessing State and Local Preparedness." The criteria in this appendix, an adaptation of criteria developed by the Preparedness Committee of the NRT, represent a basis for assessing a state or local hazardous materials emergency response preparedness program. These criteria reflect the basic elements judged to be important for a successful emergency preparedness program, which are separated into six categories: hazards analysis, authority, organizational structure, communications, resources, and emergency planning. These criteria may be used for assessing the emergency plan as well as the emergency prepared- ness program in general. Resource limitations and the results of the hazards analysis will strongly influence the necessary degree of planning and preparedness. With CHEMTREC's CHEMNET, the alignment of needs and capabilities is done over the phone by the emergency support specialist. The specialist can find contractors who have the required resource as well as their location and service area. Based on distance, the minimum response time could be estimated, but a phone call to the contractor would be required to verify the actual response time based on the location of the contractor and the location of the incident. Somewhat analogous to Canada's ERAP is the United States' Environmental Protection Agency (EPA) Risk Management Plans prepared for facilities that have highly dangerous chemicals. These plans identify the emergency response capabilities of the facilities and whether agreements were made that could be incorporated into local planning documents. If it were determined that these materials were widely shipped in the region, those capabilities could be allocated to the region. If the equipment were truly specialized, it could be documented as a state resource and other regions in the state could enter into agreement with the facility to provide emergency assistance when needed. By first identifying the resources and rolling them up to the state level, they could thereby be reallocated downward to meet the needs of smaller and more remote emergency response teams. Synopses of Stakeholder Interviews The study team conducted 16 interviews with stakeholders representing the hazardous materials and emergency response communities. Both large and small jurisdictions were repre- sented. This section summarizes the key information gathered during these interviews, orga- nized by the three methodology areas. The questions used to structure the interviews are included in Attachment 1.

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G-10 A Guide for Assessing Community Emergency Response Needs and Capabilities for Hazardous Materials Releases One knowledgeable individual indicated that quantitative approaches to risk assessment and planning were too unreliable and that qualitative approaches were highly recommended. Appropriate minimum levels of response are not possible to identify and would be nearly impos- sible to meet if they were. There is always the very-large-consequence, very-low-probability event that is often beyond the reach of most jurisdictions to be fully prepared for. Needs Assessment One interviewee stated that response needs are based on the perception of risk. Generally, formal risk analyses are rarely performed for capability assessment--mostly, this is a matching of PPE against chemicals that may be encountered. There was a universal opinion that generic community characteristics were not a good way to establish a baseline level for the presence of hazardous materials; each community was different. One individual mentioned the NFPA 1620 Standard, Pre-Incident Planning, as relevant but that it is focused on specific occupancies and properties. This would be appropriate as many large fire departments do create plans for certain facilities with hazardous materials. It was noted that transportation incidents are not currently a major focus for the NFPA. The need to update needs assessments annually was expressed by most interviewees. In California, planning is done for all hazards--and not just hazardous materials--and is updated every three years. Fixed Sources. For fixed sources, most jurisdictions rely primarily on the EPCRA Tier II reports that indicate where threshold quantities of hazardous materials are being stored. Clean Air Act Section 112 reports were also cited. One noted that these sources provide information only on the stored chemical and not the chemical that is actually released, which can differ due to reactions. One LEPC member indicated that he accessed these sources at least weekly. One local official indicated that his state identifies all facilities with "extremely hazardous substances," derived from the U.S. EPA. They plan specific responses for each of these facilities, which cover the top 10 percent of all facilities with hazmat in his region. They acquire Material Safety Data Sheet (MSDS) information for these materials and obtain the appropriate resources to respond to incidents involving them. For example, one facility contains cyanide, and the local responders have acquired a new drug that can treat cyanide exposure. Some cited the importance of institutional knowledge in augmenting their information. For example, knowing that a company produces agricultural products can provide good insight into the materials that would be used as raw materials for their manufacturing process. One regional entity (part of a large county) continually surveys industry to ensure that they are aware of the materials to which they need to respond. In California, the Office of Emergency Services pushes down identified needs to the LEPCs. Mobile Sources. For mobile sources, many jurisdictions the study team spoke with had not conducted any commodity flow surveys to identify specific hazardous materials moving through their areas, although a couple have made use of such surveys. Of those that did, most were done some time in the 1990s. One state-level official indicated that they supported local police depart- ments in conducting some commodity flow surveys. One individual expressed a concern about seasonal differences and the geographic variability of many types of material transportation. As examples, he indicated that ammonia and liquefied natural gas are more common in rural areas and there would be less home heating oil in the Midwest than in other parts of the country. One interviewee indicated that other than information from railroads, there is no useful source of information. Another indicated that his organization gets annual updates of the chem- icals transported in their area from the two Class I railroads.

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Final Report for HMCRP Project 03 G-11 Other identified sources included knowledge of the location of ports and terminals and state hazardous materials transportation routes. In some states, these routes are specific to certain materials and in others they can be more generic, applying to all hazardous materials. Capability Assessment A consistent theme from those interviewed was that the focus of response capability should be on the most likely hazards in their communities and not necessarily on the worst case. For example, one person stated that communities without a rail line should not need a chlorine kit. Another individual indicated that they do not train all teams for all the hazards they might face. A baseline definition of a team is problematic, stated one individual, because most jurisdictions-- large cities being the exception--do not have dedicated hazmat teams. Their "teams" are composed of a number of responders from different stations that come together in the event of a hazmat release. One Pipeline and Hazardous Materials Safety Administration (PHMSA) official indicated that there were approximately 1,100 hazmat teams in the United States. Some jurisdictions keep a list of resources that might be called upon to respond to certain types of incidents. Examples include soda ash, portable air compressors, and corrosive transfer capabilities. In one case, the jurisdiction would call chemical companies to locate needed items. One state indicated that they assign all teams to one of three capability levels based on their equipment, with the difference between the highest and next-highest levels being the purchase of very expensive equipment that is rarely used. There was a time, said a number of interviewees, when industry teams had more capability than public teams, but now some industries rely almost exclusively on local response. For example, one large bulk fuel storage facility only has two staff on-site at night. Some states, such as California, have very detailed emergency response capability assessment methodologies, whereas others have no statewide guidelines for rating teams at all. The California system is very similar to FEMA's Hazardous Materials Typing. In California, fire companies submit an application to the Office of Emergency Services, which performs an on-site audit, inspecting equipment and personnel records. They are in their second year of performing these inspections. To date, approximately two-thirds of all applicants fail to meet the minimum requirements. Of 127 reported hazmat teams in California, it is estimated that only about 6070 will ultimately be certified at one of the three hazmat type levels. Applicants can be a single fire company or contain personnel and resources from multiple companies. One person indicated that any rating system should come from the International Association of Fire Chiefs (IAFC), which is an organization that all jurisdictions would listen to. NPFA standards were cited as common reference point for assessing personnel and training levels. One jurisdiction assessed emergency response capability through full-scale exercises rather than through checklists or surveys. They believed this was the only effective way to comprehensively assess capability. NIMS should be a part of these exercises. Another jurisdiction has just begun to develop a methodology to conduct a survey and an assessment of local response capability. The interviewees stated that the different types of response teams (public, industry, for-hire) should be assessed differently. Facility response, for example, is focused on situations with few unknowns. For-hire responders are unlikely to be acting as first responders and will most often be involved in cleanup activities. In California, all teams would be evaluated under the same inspection parameters. One responder indicated that it would be very difficult to assess industry and contractor capability, as it is so fluid. He indicated that the local fire service responsibility was to stabilize the incident and not to clean it up. That is the responsible party's job, with the local fire service overseeing it to ensure that it is done safely.

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Final Report for HMCRP Project 03 G-21 ties. NFPA 472 (2008 Edition) defines Operations Level Responders as those "who respond to hazardous materials incidents for the purpose of implementing or supporting actions to protect nearby persons, the environment, or property from the effects of the release." Operations-level Responders are the core components of an effective response. Beyond the baseline capability, four Response Capability Tiers are defined that advance from Tier 1 with the lowest capability to Tier 4 with the highest capability. The combination of technician-level responders determines whether a hazardous materials response team meets the requirements of a specific Tier. Tiered Capability Assessment The capabilities of any resource are based upon how that resource is organized, trained, cer- tified, equipped, exercised, evaluated, and sustained. The intent of the Guide is to assess capabil- ities against existing standards whenever possible. As detailed in Section G.3, a thorough survey of existing resource typing initiatives by DHS/FEMA results in accepted, consensus-based defi- nitions for only specific elements of a public safety-based hazardous materials response and only at the highest levels of capability and capacity above the established minimum standards pre- sented within NFPA Standard 472 (2008 Edition) and 29 CFR 1910.120Q. The Guide incorporates baseline categories traditionally used by traditional public safety haz- ardous materials response teams without technician-level training, certification, and supporting equipment. The Guide was developed recognizing that many rural or remote agencies and depart- ments may employ different interpretations of these consensual standards or implement only specific portions of these consensual standards. In the Guide a fundamental assumption is that each of the jurisdictions in question has adopted the NIMS to facilitate the common exchange of information, services, and resources across jurisdictional boundaries. This NIMS component includes the standard planning and preparedness concepts in the Comprehensive Preparedness Guide 101 as well as the adoption of the ICS, the Unified Command System (UCS), and the Multi-Agency Coordination System (MACS). However, the methodology in the Guide recognizes that adoption of NIMS is not con- sistent across federal, state, tribal, and local governments, especially at the local level where fed- eral funding streams, which carry with them the mandate for NIMS-compliance, may not always drive the recommended changes in the specified time period. Since this methodology does not evaluate the overall, comprehensive, and integrated preparedness, mitigation, prevention, response, and recovery capabilities, but rather focuses on the response to hazardous materials incidents only, the expectation of NIMS compliance did not significantly skew methodology outputs and products to any noticeable degree.

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G-22 A Guide for Assessing Community Emergency Response Needs and Capabilities for Hazardous Materials Releases G.4 Guide Development and Testing Introduction Phase 2 activities for this project included developing a draft Guide; testing its use in actual, working environments; finalizing the Guide; and preparing and submitting a final project report. Draft Guide As proposed, the study team developed a Guide that is as simple and easy-to-follow as possi- ble. Where additional details, background, or advanced concepts are warranted, they are pre- sented in appendices to keep the main body and content as concise as possible. The primary sections of the Guide contains guidance on Conducting needs assessments at state, regional, and local levels; Developing, maintaining, and sharing capability assessments; Aligning assessed needs with varying levels of capability; Identifying shortfalls where additional/different capabilities are warranted; Approaches for addressing identified shortfalls. While the first four bullets cover the methodologies developed in Phase 1, the fifth bullet was not addressed in the original scope of work for this project. The study team believes that full re- alization of the value of this entire project hinges on the ability of response planning organiza- tions to not only determine whether their resources are allocated appropriately for their own needs, but that they also make appropriate adjustments if the allocation is lacking in any way. Only then will the entire jurisdiction achieve the hazardous materials emergency response cov- erage that it needs. Due to the limited funding for Phase 1 tasks, this component of the Guide was fully developed in Phase 2. In addition, the Task 3 methodology calls for maintenance components to be included, while the Task 2 methodology does not. Additional effort to determine the appropriate frequency of and procedure for refreshing the baseline needs assessment was conducted as part of Task 7, due to the funding limitations imposed on the entire Phase 1 effort. Develop Detailed Test Plan The first step was the completion of a test plan at a very detailed level. The initial version of the test plan identified the types of planners and agencies that should participate in the test, but the detailed test plan included agencies and specific individuals (or job positions) within each planning agency targeted for participation. The participants were chosen to ensure representa- tion that approximates the membership diversity of the Expert Working Group. To ensure an appropriately unbiased test, no Working Group member (neither the individual nor their agen- cies) was selected to participate in the test. Guide Testing One of the important tasks for this project is to ensure that the methodologies developed in Phase 1 and the Guide developed to assist emergency response planners in implementing the methodologies actually work in practice. This was accomplished through tests of the draft Guide conducted by practitioners with experience planning for effective emergency response to haz- ardous materials incidents. The goals of the tests of the draft Guide were to determine problem areas, errors, and omissions within the Guide by recruiting emergency response planners and experts in the field to test the draft Guide. The objective was to solicit feedback on several impor-

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Final Report for HMCRP Project 03 G-23 tant aspects of the Guide from individuals with practical experience in developing plans. Thus, the foci of the test were on receiving feedback from practitioners on various aspects of the Guide so that the Guide could be revised to enhance its overall effectiveness as an aid in planning for hazmat transportation incident response. The basic components of effectiveness include: Ease of use of the Guide (needed improvements in organization, writing style, or illustrations that would improve the Guide); Accuracy of materials in the Guide (needed corrections to materials in the Guide); and Completeness of the Guide (materials that are missing but should be included). The collected data and observations from the testers were collected so that the study team could evaluate these inputs and make the needed corrections and modifications to the Guide to improve its effectiveness. Selected Participants The study team identified a pool of planners, planning agencies, and emergency response officials that are responsible for a broad range of emergency response capabilities and located in diverse jurisdictions. Diversity included considerations such as industrial/nonindustrial, urban/rural, and small/medium/large communities; populated/sparsely populated state; and poorly/well-funded organizations. Although a diverse group of testers was selected, there was no attempt made to select a random sample. Part of the selection process included choosing candi- dates based on their familiarity with the contractor and/or members of the study team. As stated above, the participants excluded any individuals/organizations who participated in the "devel- opmental process" in Phase 1. Thirteen organizations were selected to participate in the test. The following locations and organizations were selected to test the Guide: State of Massachusetts Hazardous Materials Emergency Response; Madison County, Ohio/Environmental Protection Agency (EPA); Franklin County, Ohio CEPAC (local emergency planning committee); Yellowstone County, Montana Emergency Response; NYFD Training Center Hazmat Response; Benton County, Washington Emergency Response; Duxbury, Massachusetts LEPC; Fulton Co., NY LEPC; Onondaga County, NY LEPC; Greater Houston, Texas LEPC; Tampa Bay, Florida (LEPC); County of San Diego Hazmat Division (LEPC); and Hand County, South Dakota LEPC. Conducting the Tests Tests were implemented to gauge the Guide's effectiveness and accuracy in achieving the desired results in (a) conducting hazardous materials response needs assessments, (b) conduct- ing capabilities assessments, (c) aligning hazardous materials response needs with existing capa- bilities, and (d) identifying and providing means to correct shortfalls and inefficiencies in the capabilities as compared to the needs. The specific testing addressed two issues: (1) whether the information is presented in an understandable way (i.e., is editing required?) and (2) whether the concepts and methodologies were sound and usable. A user survey was developed to capture feedback on specific operational concepts and con- texts. The questions in the survey were developed by the study team and then reviewed by a human factors expert for objectivity and clarity, and especially to ensure that any hidden bias was uncovered. The questions were then modified based on the review by the human factors expert. The questions are included in Attachment 3.

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G-24 A Guide for Assessing Community Emergency Response Needs and Capabilities for Hazardous Materials Releases Testing Feedback As of the end of September 2010, six of the locations/organizations had conducted tests of the document and returned the questionnaire to the study team. These were the following: Madison County, Ohio/Environmental Protection Agency (EPA); Franklin County, Ohio CEPAC (local emergency planning committee); NYFD Training Center Hazmat Response; Benton County, Washington Emergency Response; Onondaga County, NY LEPC; and the Greater Houston, Texas LEPC. In general, the planners who tested the Guide assessed it to be a very useful docu- ment for assessing hazmat emergency response capabilities, determining gaps, and making de- cisions to fill in those gaps. The major criticism related to the complexity involved with following the Guide. Simply fol- lowing the assessment steps included in the Guide could be difficult for the user. Other testers expressed the desire to improve the Guide by including clearer definitions. Some of the com- ments from planners in the largest areas related to the concern that if they implemented the Guide as written, the number of hazardous material facilities and the amount of hazardous material being transported throughout the metropolitan area would make completion of the assessment a daunting task. Changing the Guide Following the tests of the Guide, a number of modifications to the Guide were made that were either based on recommendations by the test participants or identified by the study team during the test. These changes were incorporated in the draft Guide that was provided to the panel. A major change to the Guide involved adding a spreadsheet-based tool that the assessor could employ to facilitate the use of the Guide. This file is designed to follow the 20 steps outlined in the Guide. Separate tabs were developed for the major steps, and cell equations perform most of the calculations. Therefore, the assessor using the Guide is only required to follow instructions but not actually perform any calculations. For example, Steps 1 and 2 help the assessor deter- mine the current tier level of their Emergency Response organization. Steps 3 through 6 assist the assessor in selecting the proper Jurisdictional Class. The Jurisdictional Class selected deter- mines a minimum tier-level response, and if the current tier-level capability is lower than required, this is the first gap identified in this assessment. The assumption is made that this gap would be addressed before proceeding with the balance of the assessment. All of these calculations are per- formed automatically, with the planner responsible for following the instructions associated with the spreadsheet tool and entering correct data. The tool is provided on the attached CD-ROM so that an emergency response planner using the Guide can easily access the tool and use it to complement the Guide. Definitions and instructions for use of the Guide have been improved and, in some cases, added to the Guide. In other cases, instructions have been simplified to facilitate using the Guide. In response to comments from testers in large places concerned about handling the com- plexity of hazmat in their areas, instructions in the Guide were modified to accommodate these concerns. Planners in the biggest cities are now told that they might choose not to include all hazmat locations and types in their analysis. Rather, they might want to focus on only those materials with the greatest concern to their communities. These could include: highly hazardous materials that, although uncommon, if involved in an incident could result in severe conse- quences and necessitate specialized equipment and/or training for the emergency responders; hazmat where past planning may have been inadequate; and hazmat that, as demonstrated by the presence of many past incidents in the area, require special attention.

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Final Report for HMCRP Project 03 G-25 Attachment 1 Initial Interview Questions Project Overview This project will develop guidance for local communities to help them assess and understand their needs for and capacity to respond to hazardous materials incidents, whether they originate from fixed facilities or from en route events. Needs Assessment 1. For those that plan for emergency response to hazmat incidents: Please describe your process for assessing where emergency response capabilities are needed. 2. What sources do you think are best for identifying fixed locations where hazardous materials are produced, used, or stored? What types of locations are included in your analyses? [Types of fixed sources are listed on page 9 of working plan.] Do you think these are good sources? Why? How can they be improved? Do you identify the quantity and type of hazmat at these locations? If yes, how do you accomplish this? 3. What sources do you think are best for identifying the hazardous materials being transported through a community? How have you identified the quantity and type of hazmat traversing your region? What data sources did you use? [Refer to the mobile sources on page 9 of the work plan and discuss with the interviewee why other data sources were not used.] 4. Do you think that standardized "community characteristics" can be used to represent a base- line for the presence of hazmat? If not, what characteristics do you think make your commu- nity unique? How would you characterize different communities? 5. When considering both safety and security, how much of a security focus should this methodology take (for example, when dealing with the security of an iconic structure)? 6. If you perform a needs assessment, how often do you update it? Is it periodic or does some change trigger the update? If not periodic, what are the triggers? Do you update data on both fixed and mobile sources of hazmat during each update? Capability Assessment 1. For those that plan for emergency response to hazmat incidents: Please describe your process for assessing the capability level of emergency response resources. 2. What should be the focus or basis for assessing hazmat emergency response capability? For example, the hazardous materials classifications defined in the DOT regulations or types of hazards (fire, explosion, toxicity, radioactivity, and reactivity). 3. What do you think are the appropriate levels of personnel, training, and equipment for assessment? Should the InterAgency Board for Equipment Standardization and Interoperability's (IAB) Standardized Equipment List (SEL) and the DHS Office of Grants and Training's Autho- rized Equipment List be considered? Have you established your own standards? If yes, what are these standards and how did you develop them? 4. What do you think is the appropriate level of aggregation for a capability assessment (e.g., indi- vidual teams or some combination of nearby teams)? Do you find it most appropriate to train all teams for all hazards they may face? Do you distribute response capabilities across several teams? If so, what criteria do you use to assign the emergency response capabilities among the teams?

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G-26 A Guide for Assessing Community Emergency Response Needs and Capabilities for Hazardous Materials Releases 5. There are several types of response teams, including public, industry (facility and carrier), and for-hire contractors. Would you conduct capability assessments differently for these dif- ferent types? If so, how would each differ? 6. How should remote response capability that can be moved on scene as appropriate for critical needs be considered (e.g., specialized for-hire or industry teams)? 7. Besides the minimum requirement for each response team to be linked to the jurisdic- tional boundaries within which it is willing to serve, what factors should be included in multi-jurisdictional response and mutual aid agreements? 8. How should the National Incident Management System (NIMS) fit into the capability assessment? 9. How often do you think the response teams and key agencies should be resurveyed to keep this methodology up to date? Alignment 1. For those that plan for emergency response to hazmat incidents: Please describe the process used to distribute your emergency response resources. 2. What hazardous materials response teams are you aware of? How can we find these teams, and where are they? Do you rely on any national or regional level teams with specific capabil- ities that are on call? 3. What factors do you consider necessary to determine the appropriate minimum level of response for a particular area? 4. Do you think a quantitative approach is preferred to best match response capability to the areas in communities where they are most needed or can a more qualitative approach work just as well? [An example quantitative approach is using a GIS to compute or mini- mize the travel time from qualified responders to all locations on the road network in a community.] Would a different approach be warranted for agencies that had different sized budgets or existing resources (such as GISs) for hazmat emergency response planning? 5. What is an appropriate minimum level of response for a given: Community Region State 6. What do you think an organization needs to look at when considering spending additional resources on improving existing teams, creating new teams, or relocating existing teams to better align with their needs? 7. How do you think investment across jurisdictions be addressed? [For example, it may be cheaper to buy some equipment for a nearby team in a neighboring jurisdiction to bring them up to a needed capability level than it would be to create a new team.] End of Interview Is there anyone else that we should talk to or be aware of? Are there any other communities or groups that you recommend we talk to? Is this person a good candidate for the Expert Working Group? If so, ask if he/she would be interested (not a commitment) to help review interim work products, etc. We are only looking for interest at this point, so we can select candidates and have the Project Panel approve them.

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Final Report for HMCRP Project 03 G-27 Attachment 2 Expert Working Group This attachment lists the members of the Expert Working Group assembled to assist the project team to develop the key methodologies in Tasks 2 through 4 of the project. Expert Working Group Member Rationale James Bowden Served as the Deputy Director for the City of Nashville Emergency Management Specialist Office of Emergency Management and as an Emergency ResponseForce1 Management Specialist for General Physics Corp (part Nashville, TN of the Katrina recovery). He is also currently a subject matter expert for Previstar. Jan Dunbar Was involved with the creation of California's Assistant Chief--Special Operations FIRESCOPE Standardized Equipment List (SEL). His Fire / Rescue Branch current duties at OES include conducting California Office of Emergency Services inspections/audits of applicant hazmat teams in order to Sacramento, CA assess their capabilities and resources against the state's hazmat team typing criteria. James Field Member of two LEPCs in Massachusetts as well as Hazardous Materials Control Manager Hazmat Control Manager at UMass. University of Massachusetts Environmental Health & Safety Amherst, MA Dick Hopkins Fire Captain for many years in Hagerstown, MD, Hazmat Coordinator valuable for his smaller community perspective. In his International Association of Fire Fighters current position as hazmat coordinator for IAFF, he is Washington, DC aware of the latest hazmat training courses and requirements for fire departments. Greg Noll He serves as the Program Manager for the South Central Program Manager Pennsylvania Regional Counter-Terrorism Task Force as South Central Task Force well as the Hazmat/WMD Manager for the PA Task and Force-1 urban search and rescue unit. Greg served as Senior Partner the Hazardous Materials Coordinator with the Prince George's County, MD, Fire Department where he Hildebrand Noll Associates managed the Level III Hazardous Materials Team. Lancaster, PA Bill Pintorak Head of the Northwest Strike team, composed of fire Captain departments in the vicinity of Columbus, OH, that have Liberty Township Fire Department banded together for hazmat response. This team Liberty, OH demonstrates how smaller satellite communities can contribute their own hazmat response specialties, resulting in a team that is much stronger and more versatile than its individual members. Alan Williams Leads response planning at the state level and is also Program Manager very involved with South Baltimore Industrial Mutual Emergency Response & Planning Program Aid Plan (SBIMAP), which fosters chemical emergency Maryland Department of the Environment preparedness, renders mutual aid in the event of an Baltimore, MD emergency, and facilitates cooperation between citizens groups, public agencies, and industry.

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G-28 A Guide for Assessing Community Emergency Response Needs and Capabilities for Hazardous Materials Releases Attachment 3 Survey Questions for Guide Testers Questions for Guide Testers 1. Please provide the following information: Name Title Agency Area Covered Contact Information Phone Email Mailing Address 2. Is the purpose of the Assessment Guide clear to you? Yes___ No___ 3. Did you find the content of the Guide useful? Yes___ No___ 4. Will the information in the Guide help you assess your community's emergency response needs and capabilities? Yes___ No___ 5. Did you find the overall process clearly described and easy to follow? Yes___ No___ 6. Were any parts of the process difficult to follow? Yes___ No___ If yes, which parts were difficult to follow? 7. For those parts that were difficult to follow, how do you think they could be improved? 8. Did you have any trouble understanding the instructions for any of the steps? Yes___ No___ If Yes, list the steps you think need improvement. Include a list of any steps that are unclear or incomplete and explain what you think are the shortcomings. 9. When reading the Guide, did you need to look up terms using outside sources? Yes___ No___ If Yes, which terms did you look up?

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Final Report for HMCRP Project 03 G-29 10. Are there any additional procedures or steps that you think should have been included in the Guide? Yes___ No___ If Yes, list the additional procedures or steps you think should be included and in what sec- tion of the Guide you think they should appear. 11. Were you able to use the Guide to quantify/categorize the hazardous material being trans- ported in or through your region and/or were present at fixed facilities? Yes___ No___ If No, explain what you are unable to complete and why? 12. Using the Guide, could you identify the capabilities needed to respond to incidents in your area based on the hazardous material present? Yes___ No___ If No, what difficulties did you encounter? 13. Using the Guide, do you feel you could identify the needed capabilities of response teams for your area and the information necessary to assess their response capabilities? (this would include such elements as equipment, number of trained personnel, medical surveillance, and site planning) Yes___ No___ If No, what impediments did you find? 14. Does the Guide identify capabilities that exceed or are less than what is needed for success- ful emergency response in your area? Yes___ No___ If No, what steps should be included in the Guide to provide this information? 15. Are there operationally relevant capabilities or situations in your region that do not fit into the capability categories described by the Guide? Yes___ No___ If Yes, list and describe these capabilities and/or situations. 16. For gaps in the hazardous material emergency response coverage that you identified, were you able to successfully use the Guide to identify the additional capabilities needed to pro- vide complete coverage? Yes___ No___ If No, please describe those areas where the Guide was inadequate.

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G-30 A Guide for Assessing Community Emergency Response Needs and Capabilities for Hazardous Materials Releases 17. Are you able to use the Guide to successfully create a complete record for your response team's capabilities? Yes___ No___ If No, please describe any areas where the Guide fell short. 18. Is the overall process described in the Guide too complex? Yes___ No___ If Yes, please provide your suggestions for simplifying it? 19. If you were asked to perform a hazard response assessment, is there any information or data that you would find difficult to obtain? Please list the steps that would be difficult to com- plete and provide a description of specific information or data needs. 20. Were the terms used to calculate the Risk Metric clearly defined? Yes___ No___ 21. Are there any terms in the Risk Metric that you feel are not needed? Yes___ No___ If Yes, please list. 22. Are there additional terms that you think should have been included in the Risk Metric? Yes___ No___ If Yes, please describe what terms were missing. 23. Would worksheets designed to walk the reader through the steps in the Guide be of value? Yes___ No___ If Yes, would worksheets designed to automatically calculate the Risk Metric once all data were entered help you follow the steps in the Guide? Yes___ No___ 24. Once you used the Guide and had developed a complete record of all hazardous material lo- cations and transport corridors, emergency response locations and capabilities, jurisdic- tional performance objectives, etc., do you think that the structure provided by the Guide would facilitate regular (perhaps annual) update and review cycles? Yes___ No___ If No, please describe where the Guide fell short.

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Final Report for HMCRP Project 03 G-31 25. Do you think the structure provided by the Guide would facilitate sharing the data and in- formation on the presence of hazardous materials and response capabilities with other neighboring jurisdictions? Yes___ No___ If No, please describe where the Guide fell short. 26. Do you have a process already in place to determine the information requested in the Guide? Yes___ No___ If Yes, Please describe this process.