CHEMICAL STOCKPILE EMERGENCY PREPAREDNESS PROGRAM

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RECOVERY PLAN WORKBOOK

*Disclaimer*

This report was prepared as an account of work sponsored by an agency of
the United States Government. Neither the United States Government nor
any agency thereof, nor any of their employees, makes any warranty,
express or implied, or assumes any legal liability or responsibility for
the accuracy, completeness, or usefulness of any information, apparatus,
product, or process disclosed, or represents that its use would not
infringe privately owned rights. Reference herein to any specific
commercial product, process, or service by trade name, trademark,
manufacturer, or otherwise, does not necessarily constitute or imply its
endorsement, recommendation, or favoring by the United States Government
or any agency thereof. The views and opinions of authors expressed
herein do not necessarily state or reflect those of the United States
Government or any agency thereof.

**CSEPP RECOVERY PLAN WORKBOOK**

**April 2003**

Developed by

Argonne National Laboratory

Decision and Information Sciences Division

for

U.S. Army Soldier and Biological Chemical Command

Federal Emergency Management Agency

CSEPP Reentry and Recovery Working Group

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**CONTENTS**

[1 INTRODUCTION 1](#introduction)

[1.1 Purpose of This Workbook 1](#purpose-of-this-workbook)

[1.2 Context of Recovery from a Chemical Event
1](#context-of-recovery-from-a-chemical-event)

[1.2.1 General Assumptions 2](#general-assumptions)

[1.2.2 Assumptions for Severe Events 2](#assumptions-for-severe-events)

[1.3 Structure and Contents of the Workbook
4](#structure-and-contents-of-the-workbook)

[1.4 Using the Workbook 4](#using-the-workbook)

[1.5 Recovery in an ICS -- Based Organization
5](#recovery-in-an-ics-based-organization)

[2 MODEL RECOVERY PLAN 9](#model-recovery-plan)

[2.1 Promulgation 9](#promulgation)

[2.1.1 Approval by Designated Authorities
9](#approval-by-designated-authorities)

[2.1.2 Record of Revisions 11](#record-of-revisions)

[2.1.3 Distribution List 12](#distribution-list)

[2.2 BASIC PLAN 13](#basic-plan)

[2.2.1 Purpose 13](#purpose)

[2.2.2 Relationship Between Emergency Response and Recovery
13](#relationship-between-emergency-response-and-recovery)

[2.2.3 Definitions 13](#definitions)

[2.2.4 Related Plans 14](#related-plans)

[2.2.5 Direction and Control 14](#direction-and-control)

[2.2.6 Recovery Organization 15](#recovery-organization)

[2.2.7 Plan Maintenance 16](#plan-maintenance)

[2.2.8 Training 16](#training)

[2.2.9 Exercises 17](#exercises)

[2.3 HAZARD ASSESSMENT 19](#hazard-assessment)

[2.3.1 Purpose 19](#purpose-1)

[2.3.2 Concept of Operations 19](#concept-of-operations)

[2.3.3 Monitoring and Sampling Priorities
20](#monitoring-and-sampling-priorities)

[2.3.4 Monitoring and Sampling Resources
29](#monitoring-and-sampling-resources)

[2.3.5 Responsibilities by Position/Organization
31](#responsibilities-by-positionorganization)

[2.3.6 ICS -- Based Responsibilities 33](#ics-based-responsibilities)

[2.4 ACCESS TO RESTRICTED AREAS 35](#access-to-restricted-areas)

[2.4.1 Purpose 35](#purpose-2)

[2.4.2 Assumptions 35](#assumptions)

[2.4.3 Concept of Operations 35](#concept-of-operations-1)

[2.4.4 Tasks and Personnel in Restricted Areas
36](#tasks-and-personnel-in-restricted-areas)

[2.4.5 Procedures for Access and Personnel Protection
37](#procedures-for-access-and-personnel-protection)

[2.4.6 Responsibilities by Position/Organization
38](#responsibilities-by-positionorganization-1)

[2.4.7 ICS -- Based Responsibilities 40](#ics-based-responsibilities-1)

**CONTENTS cont\'d**

[2.5 INGESTION PATHWAY PROTECTION 43](#ingestion-pathway-protection)

[2.5.1 Purpose 43](#purpose-3)

[2.5.2 Concept of Operations 43](#concept-of-operations-2)

[2.5.3 Identification of Potential Ingestion Pathway Concerns
45](#identification-of-potential-ingestion-pathway-concerns)

[2.5.4 Authority for Ingestion Pathway Protection
46](#authority-for-ingestion-pathway-protection)

[2.5.5 Ingestion Pathway Exposure Hazard Assessment
47](#ingestion-pathway-exposure-hazard-assessment)

[2.5.6 Ingestion Pathway Protective Actions
47](#ingestion-pathway-protective-actions)

[2.5.7 Responsibilities by Position/Organization
48](#responsibilities-by-positionorganization-2)

[2.5.8 ICS -- Based Responsibilities 49](#ics-based-responsibilities-2)

[2.6 MEDICAL SERVICES 51](#medical-services)

[2.6.1 Purpose 51](#purpose-4)

[2.6.2 Assumptions 51](#assumptions-1)

[2.6.3 Concept of Operations 51](#concept-of-operations-3)

[2.6.4 Responsibilities by Position/Organization
54](#responsibilities-by-positionorganization-3)

[2.6.5 ICS -- Based Responsibilities 56](#ics-based-responsibilities-3)

[2.7 RELOCATION 59](#relocation)

[2.7.1 Purpose 59](#purpose-5)

[2.7.2 Concept of Operations 59](#concept-of-operations-4)

[2.7.3 Responsibilities by Position/Organization
61](#responsibilities-by-positionorganization-4)

[2.7.4 ICS -- Based Responsibilities 62](#ics-based-responsibilities-4)

[2.8 SOCIAL SERVICES 63](#social-services)

[2.8.1 Purpose 63](#purpose-6)

[2.8.2 Concept of Operations 63](#concept-of-operations-5)

[2.8.3 Services Provided 63](#services-provided)

[2.8.4 Participating Agencies and Organizations
64](#participating-agencies-and-organizations)

[2.8.5 Responsibilities by Position/Organization
64](#responsibilities-by-positionorganization-5)

[2.8.6 ICS -- Based Responsibilities 65](#ics-based-responsibilities-5)

[2.9 PUBLIC INFORMATION 67](#public-information)

[2.9.1 Purpose 67](#purpose-7)

[2.9.2 Assumptions 67](#assumptions-2)

[2.9.3 Concept of Operations 68](#concept-of-operations-6)

[2.9.5 Transition from Emergency Phase Public Information Operation
69](#transition-from-emergency-phase-public-information-operation)

[2.9.7 Responsibilities by Position/Organization
70](#responsibilities-by-positionorganization-6)

[2.9.8 ICS -- Based Responsibilities 71](#ics-based-responsibilities-6)

[2.10 CLAIMS AND DISASTER ASSISTANCE
73](#claims-and-disaster-assistance)

[2.10.1 Purpose 73](#purpose-8)

[2.10.2 Concept of Operations 73](#concept-of-operations-7)

[2.10.4 Responsibilities by Position/Organization
74](#responsibilities-by-positionorganization-7)

[2.10.5 ICS -- Based Responsibilities 76](#ics-based-responsibilities-7)

**CONTENTS cont\'d**

[2.11 ENVIRONMENTAL REMEDIATION 79](#environmental-remediation)

[2.11.1 Purpose 79](#purpose-9)

[2.11.2 Assumptions 79](#assumptions-3)

[2.11.3 Concept of Operations 79](#concept-of-operations-8)

[2.11.4 Responsibilities by Position/Organization
81](#responsibilities-by-positionorganization-8)

[2.11.5 ICS -- Based Responsibilities 82](#ics-based-responsibilities-8)

[ANNEX A: SITE-SPECIFIC INFORMATION
87](#annex-a-site-specific-information)

[ANNEX B: EXTERNAL SUPPORT 89](#annex-b-external-support)

[ANNEX C: VOLUNTEER AND FAITH-BASED](#annex-c-volunteer-and-faith-based)
[RELIEF ORGANIZATIONS 91](#relief-organizations)

[ANNEX D: TECHNICAL CONTACTS 97](#annex-d-technical-contacts)

[ANNEX E: PERSONAL PROTECTIVE EQUIPMENT
99](#annex-e-personal-protective-equipment)

[ANNEX F: CHEMICAL AGENT EXPOSURE STANDARDS
101](#annex-f-chemical-agent-exposure-standards)

[ANNEX G: ANALYTICAL LABORATORIES 109](#annex-g-analytical-laboratories)

[ANNEX H: CLEANUP PROCEDURES UNDER](#annex-h-cleanup-procedures-under)
[CERCLA AND RCRA 113](#cercla-and-rcra)

[ANNEX I: MILITARY CLAIMS AUTHORITY
117](#annex-i-military-claims-authority)

[ANNEX J: RESPONSE COSTS UNDER CERCLA
123](#annex-j-response-costs-under-cercla)

[ANNEX K: DISASTER ASSISTANCE UNDER](#annex-k-disaster-assistance-under)
[THE STAFFORD ACT 131](#the-stafford-act)

[ANNEX L: STATE EMERGENCY PREPAREDNESS STATUTES
141](#annex-l-state-emergency-preparedness-statutes)

[ANNEX M: RECOVERY PLANNING IN AN
INCIDENT](#annex-m-recovery-planning-in-an-incident)

[COMMAND SYSTEM CONTEXT 149](#command-system-context)

[ANNEX N: ACRONYMS 151](#annex-n-acronyms)

[ANNEX O: BIBLIOGRAPHY 155](#annex-o-bibliography)

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# 1 INTRODUCTION

## 1.1 Purpose of This Workbook 

The Recovery Plan Workbook is designed for use by U.S. Army chemical
installations and state and local authorities who participate in the
Chemical Stockpile Emergency Preparedness Program (CSEPP). The Workbook
includes a model recovery plan that provides a template for preparation
of an integrated CSEPP recovery plan. The Workbook also provides
background, explanatory and reference materials to aid planners.

The model plan provides a general example and framework for planning,
but is not complete without input from the local CSEPP Community. Each
chemical stockpile location has site-specific needs, resources, and
organizational differences that will shape recovery planning. Therefore
the purpose of the model plan, in part, is to raise questions that
installation, state and local planners will have to answer in order to
develop a site-specific recovery plan.

It is recommended that a single, overarching recovery plan be developed
to coordinate the activities of the installation, state and local
jurisdictions at a given site. As stated in the CSEPP Planning Guidance,
Appendix M, "The reentry/restoration plan should be integrated and
coordinated among the Army installation and other state and local
jurisdictions in the IRZ and PAZ." The integrated approach is more
efficient from a planning perspective (compared to separate, parallel
plans for each jurisdiction) and will facilitate coordination among the
organizations. Also, many aspects of recovery must be coordinated in
order to be effective; for example, if several jurisdictions put in
competing requests to the Army for monitoring services, confusion might
result and some important monitoring activities might be delayed. A
coordinated plan would ensure that monitoring is conducted in proper
order of priority.

A single integrated recovery plan can be designed to accommodate the
decision making prerogatives of all included organizations.
Jurisdiction-specific annexes may be appropriate in some cases to
accommodate the unique needs of particular jurisdictions.

## 1.2 Context of Recovery from a Chemical Event

It is impossible to predict the exact situation that would follow in the
aftermath of a chemical event. Much would depend on the origin of the
event, the severity of the event, the response to it, and other
parameters such as the weather. However, at least some circumstances may
be anticipated in advance, and this workbook is based on those
assumptions to a considerable extent. Planning for recovery should take
account of the probable circumstances and should incorporate measures to
address the issues they will raise.

It should be noted that a chemical event may or may not involve a
release of chemical agent, and where there is a release, it may or may
not be enough to be detectable or pose a hazard off-post. A recovery
process should be considered for any chemical event in which the public
is notified of an emergency. However, the recovery process will be
simpler if, after the situation is assessed, it is determined that there
was no release or a minimal release. The Workbook is not based on any
assumption as to the severity of the event; it is intended to cover the
full range of chemical events ranging from purely precautionary notices
to severe events involving significant hazards off-post.

### 1.2.1 General Assumptions

The following assumptions apply to any chemical stockpile emergency
where the off-post community is involved, whether or not any actual
release of chemical agent is confirmed.

• If any area has been evacuated or access to it restricted, there will
be pressure to re-open it so that people may return to their homes and
businesses.

• Once protective actions of any kind have been issued, the population
near the facility will want reassurance that the area is safe.

• Recovering from the medical, social, psychological and economic
impacts of the event will take a much longer period than the physical
process of recovery.

• Recovery operations and decisions will be subject to intense scrutiny
from news media and from elected officials at the state and federal
level.

### 1.2.2 Assumptions for Severe Events

For severe events where there is a significant release of chemical agent
and a possibility that it was transported off-post, it can be
anticipated that there will be uncertainty as to the nature and extent
of any residual hazard. Protective actions will likely have been
initiated based on assumptions as to the amount of agent released (e.g.,
the maximum credible event or MCE), combined with computer modeling of
its dispersal. The process of determining whether there is any residual
hazard will likely take a few days to a few weeks. If investigation at
the scene of the event reveals no releases, that period might be
reduced. If investigation or monitoring indicates a possibility of
aerosol deposition, that period might be increased.

In such an event, off-post officials would have a number of concerns
relating to monitoring, sampling, hazard assessment, and protective
actions during the recovery period, specifically including:

• Concern for residual agent vapor. The agent vapor that is released by
an accident is carried downwind and dissipates soon after the release is
controlled, except possibly within buildings where vapors might linger
for some additional short period. There is also the remote possibility
of materials inside of buildings absorbing agent vapors if vapor
concentrations are extremely high, such as close to the site of the
release, and thus posing a temporary residual hazard even though there
is no longer a hazard outdoors.

• Concern for aerosol deposition. Under some circumstances, it is
possible that chemical agent would be dispersed as an aerosol (very
small droplets) and subsequently deposited as contamination on downwind
surfaces off-post. Studies have shown that this is unlikely to occur,
and if did occur it would be limited to a small area near the
installation. An unusual combination of factors is needed to make
aerosol deposition a possible health risk beyond the installation
boundary: detonation of a number of explosively configured munitions
filled with persistent agent (VX or mustard), combined with a fire hot
enough to cause the munitions to detonate and carry the aerosols well
above ground level in a heated plume. In addition, the right atmospheric
conditions are needed to transport the aerosol significant distances in
order for the droplets to fall out beyond the installation boundary.

• Concern for unprotected persons remaining in the restricted area. It
is likely that some persons will have remained in the area at risk
regardless of the protective action instructions they were given. These
persons might require help in relocating.[^1]

• Concern for special populations in pressurized shelters. Special
populations might need outside assistance to resolve health and safety
issues at their location before they are free to exit the shelter.

• Concern for additional releases. In some scenarios there may be a
slight possibility for additional releases over time, for example as
damaged munitions are being handled as part of the site clean-up.

• Concern for other hazards caused by the chemical event. The chemical
event may cause secondary hazards in the affected area. For example,
rapid evacuation of the population might leave some industrial
facilities or critical infrastructures vulnerable to loss or damage
that, in turn, could pose a health and safety threat. Traffic accidents
on evacuation routes in the hazard area might create situations that
necessitate response in potentially hazardous areas to save lives.

• Concern for other hazards not caused by the chemical event. Disasters
such as earthquakes or tornadoes might cause or contribute to a chemical
event, create separate response requirements, and complicate the
chemical event response.

• Concern for those who evacuated from areas that were never at risk.
Because of the conservative assumptions that are built in to the
protective action decision making process, it is likely that many people
will have evacuated from areas that were never dangerous. This
population will strain resources to provide care and shelter for
evacuees until they return home.

## 1.3 Structure and Contents of the Workbook

The remainder of this Workbook consists of two main parts: a model plan
and a set of annexes.

The model plan consists of eleven sections: promulgation materials, a
basic plan, and nine function-specific sections. The basic plan
summarizes the overall purpose, assumptions, and responsibilities for
recovery operations. It defines basic aspects of implementation such as
how recovery efforts are initiated and ended, and how the recovery plan
relates to the emergency phase response plan. The basic plan also
addresses administrative issues such as authority for planning and
response, exercises and drills, and mechanisms for revising and updating
the plan. Following the basic plan are the function-specific sections.
The functional sections address specific aspects of recovery operations
and outline how they will be implemented. Each functional section
includes a statement of purpose, concept of operations,
function-specific details, and lists of responsibilities for key
organizations and officials.

Supplementing the model plan are a set of annexes. The annexes address a
number of topics that directly relate to recovery and restoration
activities. The topics include technical resources, social service
resources, summaries of applicable laws and regulations, and other items
of interest for recovery planning. The annexes are intended to provide
background materials for planners and can also serve as a basis for
developing site-specific implementation procedures for the recovery
plan. Annex N contains a list of CSEPP-related acronyms. Annex O
contains a bibliography of recovery-related documents and information
sources.

## 1.4 Using the Workbook

[The Reentry/Recovery Planning Process and Planning Team]{.underline}

The model plan is designed to accommodate user input. In fact, the plan
is incomplete without additional information that only the user can
provide. A planning team should be assembled to develop a customized,
site-specific plan from the model plan.

The reentry/recovery planning team ideally should include
representatives of the installation, local jurisdiction(s) and state(s).
The draft reentry/recovery plan should be reviewed by appropriate
officials of these organizations and by technical and legal experts as
requested by the planning team.

[Creating a Site-Specific Recovery Plan]{.underline}

The model plan is designed to serve as a template or outline for
creating a customized, site-specific, integrated recovery plan. The
basic components of a recovery plan are included, but they will need to
be expanded with specific local information to create a site-specific
plan. A symbol \[=**\>**\] indicates places where it is anticipated that
the user will insert specific local information. In addition, the model
plan contains explanatory materials throughout the text. The explanatory
material is in *italics* to distinguish it from the plan text. This
italicized text is not intended to be incorporated into the plan and
should be deleted when the plan is complete.

The wording, organization, and all other aspects of the model plan are
intended as suggestions only and should be modified to fit the user's
needs. The design, format, and use of graphics in the model plan were
deliberately kept simple to facilitate manipulation of the document.

The model plan was designed as a stand-alone plan and can be developed
as such. Alternatively, the plan can be attached as an annex to other
response or recovery plans. Similarly, function- or
organization-specific procedures or annexes may be added to the recovery
plan.

As noted in section 1.1 above, a single integrated recovery plan is
recommended. Because such a plan may span several organizations, it is
important that it be specific with respect to what positions and
agencies, at what levels, will make key decisions and carry out key
functions. Throughout the model plan are entries that stand in for
particular jurisdiction names or position titles. These entries are
*[underlined and in italics]{.underline}*. For example the phrase *[name
of jurisdiction]{.underline}* is used where a jurisdiction's name (e.g.
"Smith County" or "State of Jones") would go, and *[chief
executive]{.underline}* is used where a finished plan would contain the
applicable position title such as "Installation Commander," "Governor"
or "County Board Chair." Depending on local arrangements, at some points
in the plan these phrases might instead be replaced with the name of a
committee or a general phrase such as "each organization." Generic
agency names such as *[social service agency]{.underline}* or
*[environmental protection agency]{.underline}* are used where
particular agency names should appear.

Development of a recovery plan will likely require site-specific
information on land use, population demographics, presence of special
populations and facilities, and so on. Annex A contains a list of
possible sources for such information.

## 1.5 Recovery in an ICS -- Based Organization

The model recovery plan in this document is intended to be compatible
with various types of chemical event response plans and organizational
schemes, including the Incident Command System (ICS). Annex M provides a
brief overview of the relationship between recovery planning as embodied
in the model plan and the ICS method of response organization.

For those organizations intending to use the ICS during recovery
operations, the model plan includes ICS-based responsibilities for each
recovery function. Like all other aspects of this document, these
subsections are only suggestions and should be modified as desired to
fit local needs. Please note that the ICS-based responsibilities only
include actions that would be performed during recovery from a chemical
emergency, whereas the position and organization-based responsibilities
also include (in some cases) planning functions that should be performed
in advance of any emergency. Therefore, organizations that plan to use
the ICS for chemical emergency recovery may find that *both* the
ICS-based and the position/organization-based responsibility lists are
relevant for recovery planning.

A chemical stockpile accident or incident with potential or actual agent
impacts off-post raises a series of inter-jurisdictional challenges
regarding the issue of "who is in charge", in both the response and
recovery phases of the incident. The Incident Command System (ICS)
provides a means to meet those challenges, whether it is organized as a
single or unified (multi-agency, multi-jurisdictional) command. A key
element in effectively applying ICS is first understanding who the
Incident Commander works for. In general ICS terms, the Agency
Administrator is the authority having jurisdiction over and
responsibility for the role the Incident Commander takes in the
management of an incident. In other words, the Agency Administrator is
who the Incident Commander works for when assigned to an incident. (In a
CSEPP application, the Agency Administrator could be a County
Commissioner, State Governor, Secretary of Defense, the President, or
other key officials. Under a unified command structure, there could be
an Agency Administrator from local, state and federal government.)

The Agency Administrator is not only responsible for the incident's
outcome, but is responsible for other activities that may occur as part
of the job. The Incident Commander is responsible to the Agency
Administrator for the administration and management of the assigned
incident, and all activities that occur on the incident.

The Agency may be represented specifically within the Incident Command
System in two other ways. First, the Agency Advisor is an individual who
has been designated by the Agency Administrator to work directly with
the Incident Commander. Second, the Agency Representative is an
individual who represents the Agency Administrator on specific policy
matters from the agency. Generally, the Agency Representative will not
be assigned at a level between the Incident Commander and the Agency
Administrator. This position most often comes into play when resources
are assigned to a non-jurisdictional incident and representation of the
agency is important. The Agency Representative usually works with the
Liaison Officer, an ICS Command Staff position.

The value of applying the Incident Command System to CSEPP response and
recovery is that is neither a unique nor an untested system. It is
applied to civilian incidents involving fire, hazardous materials, law
enforcement, search and rescue, mass causalities, etc. ICS training is
available nationwide at a range of levels, i.e., Introduction (ICS-100),
Basic (ICS-200), Intermediate (ICS-300), Advanced (ICS-400) and ICS-402
for Executives. From a military perspective, ICS provides a welcome
structure to civilian response.

The bibliography in Annex O includes general references on the Incident
Command System.

**MODEL RECOVERY PLAN**

\[blank page\]

# 2 MODEL RECOVERY PLAN

## 2.1 Promulgation 

### 2.1.1 Approval by Designated Authorities

The attached recovery plan is hereby approved as the basis of integrated
chemical event recovery operations for *[names of
organizations]{.underline}*.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_

*([name and title of chief executive]{.underline})* Date

*[Jurisdiction A]{.underline}*

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_

*([name and title of chief executive]{.underline})* Date

*[Jurisdiction B]{.underline}*

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_

*([Name, Commander]{.underline})* Date

*[Installation Name]{.underline}*

\[blank page\]

### 2.1.2 Record of Revisions

+-------------+-----------------------------+-------------------------+
| **Date**    | **Pages Revised**           | **Pages Updated By:**   |
|             |                             |                         |
|             |                             | **(name)**              |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+
|             |                             |                         |
+-------------+-----------------------------+-------------------------+

### 2.1.3 Distribution List

+----------------------+------------------------------------+----------+
| **Organization**     | **Contact Information**            | **Date   |
|                      |                                    | and Copy |
|                      | **(position or title, address,     | No.**    |
|                      | telephone, email)**                |          |
+----------------------+------------------------------------+----------+
|                      |                                    |          |
+----------------------+------------------------------------+----------+
|                      |                                    |          |
+----------------------+------------------------------------+----------+
|                      |                                    |          |
+----------------------+------------------------------------+----------+
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+----------------------+------------------------------------+----------+
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|                      |                                    |          |
+----------------------+------------------------------------+----------+
|                      |                                    |          |
+----------------------+------------------------------------+----------+
|                      |                                    |          |
+----------------------+------------------------------------+----------+

## 2.2 BASIC PLAN

### 2.2.1 Purpose

This Recovery Plan is designed to support activities that occur in the
recovery phase following a chemical event at *[name of
installation]{.underline}*. The term "recovery" includes measures to
assess the hazard and perform other urgent tasks in the area affected by
the emergency; a controlled process for reentry, restoration, and
remediation; and provision of services to persons, businesses and other
organizations affected by the emergency. The primary purpose of recovery
activities is to protect public health and safety while returning the
community to normal conditions.

### 2.2.2 Relationship Between Emergency Response and Recovery

Emergency response and recovery have the same overall goal, protecting
public health and safety and the environment. Emergency response focuses
on immediate protective measures to mitigate the source of the hazard
and to prevent or minimize the public's exposure to the hazard. Reentry
and recovery focus on returning life in the affected area to normal,
while ensuring that safety and health standards are maintained. Although
it is sometimes convenient to refer to emergency phase activities and
recovery phase activities, there is no sharp boundary between the two
phases. Activities to support reentry and recovery begin as soon as
possible after a chemical event, as information is gathered to analyze
the hazard and resources are activated to support the affected
population.

### 2.2.3 Definitions 

[Hazard Area]{.underline}: An area where there is or has been a chemical
agent hazard, according to computer dispersion modeling and/or
monitoring results.

[Recovery]{.underline}: Recovery is a phase of emergency management.
Recovery includes both short- and long-term activities. Short-term
recovery activities may include reentry to the restricted area to
perform vital missions; hazard assessment (monitoring and sampling); and
provision of services to meet the immediate needs of evacuees and other
persons affected by the emergency. Long-term recovery activities may
include continuing hazard assessment, environmental remediation, social
services for persons affected by the emergency, compensation for persons
and organizations that suffered financial losses, and other activities
to restore the community to a normal or near-normal state.

[Restricted Reentry]{.underline}: Temporary, short-term admission of
persons into a restricted area for the purpose of performing some
essential task.

[Unrestricted Reentry]{.underline}: Unrestricted admission of the public
into a previously restricted area.

[Restricted Area]{.underline}: An area subject to protective actions
involving restriction on entry; generally, an area in which the public
has been advised to evacuate or to shelter-in-place and then relocate.
The restricted area will contain the hazard area and will usually be
larger than it.

### 2.2.4 Related Plans

This plan has been developed consistent with other plans affecting
recovery from a chemical event, including *[local and state CSEPP
response plans]{.underline}*, the *[name of installation]{.underline}*
Chemical Accident/Incident Response and Assistance (CAIRA) plan, the
Service Response Force (SRF) Commander's Plan, the National Contingency
Plan (NCP), and the Federal Response Plan (FRP).

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(*Include any other relevant plans*.)

### 2.2.5 Direction and Control

*[The County/State Chief Executive]{.underline}* will make decisions
regarding reentry to off-post restricted areas and lifting of general
population protective actions. *[Name of jurisdiction]{.underline}* will
take the lead in coordinating provision of *[County/State]{.underline}*
services to persons and organizations affected by the emergency.

The U.S. Army will take the lead with respect to hazard assessment,
including environmental monitoring, sampling and evaluation; cleanup of
residual hazards and other response and remediation under the NCP, and
payment of claims for compensation by persons or organizations that
suffered financial losses as a direct result of the emergency. Army
operations will be directed initially by the Installation Commander;
subsequently direction of some or all of these functions may be
transferred to the SRF Commander.

The Federal Emergency Management Agency (FEMA) will coordinate provision
of disaster assistance under the Stafford Act and the FRP.

The U.S. Department of Justice (DOJ) will take the lead in crisis
management and investigation both on-post and off-post in the event of
terrorist or criminal activity associated with a chemical incident.

The *[U.S. Department of Agriculture (USDA) and Food and Drug
Administration (FDA) and/or State Department of Agriculture, State
Department of Health, State Department of Environmental
Protection]{.underline}* will take the lead with respect to developing
and implementing protective measures for food, water and drugs.

All agencies and jurisdictions involved in recovery will coordinate
recovery operations through the Executive Group, Technical Group,
Operations Group, and such other groups and committees as may be formed
to facilitate recovery.

(*Note: completing the first paragraph of this section will depend on
local circumstances and what organizations are included in the recovery
plan. The decision-making roles of state and local chief executives vary
from state to state and may change depending on the declaration of a
state or local State of Emergency. The state emergency management
statute generally will control those functions; Annex L has brief
summaries of the statutes for the CSEPP states.*

*In general, state-wide direction and control is recommended for the
reasons stated in the Workbook introduction. In the fifth paragraph,
responsibilities for protection of food, water and drugs may be at the
federal or state level depending on whether state agencies have received
federal approval to be the enforcement authority under the applicable
statute.*)

### 2.2.6 Recovery Organization

The recovery organization will include the following groups: Executive
Group, Operations Group, and Technical Group.

The Executive Group will consist of the *[Installation
Commander]{.underline}* and the following state/local officials: *[Chief
Executive]{.underline}*, *[Public Information Officer]{.underline}*, and
the heads of the *[Emergency Management Agency]{.underline}*,
*[Environmental Protection Agency]{.underline}*, *[Law Enforcement
Agency]{.underline}*, and *[Public Health Agency]{.underline}*. The
Executive Group will assist with recovery decision making and coordinate
with other jurisdictions and organizations.

The Operations Group will consist of representatives of the Installation
operations staff and the following state/local agencies: *[Emergency
Management Agency]{.underline}*, *[Environmental Protection
Agency]{.underline}*, *[Law Enforcement Agency]{.underline}*,
*[Hazardous Materials Response Agency]{.underline}* and *[Public Health
Agency]{.underline}*. The Operations Group will advise the Executive
Group and will manage implementation of recovery actions. The Operations
Group will maintain contact and coordination with operations groups at
other involved organizations, as well as the Joint Information Center.

The Technical Group will consist of representatives of the Installation
technical staff and the following state/local agencies: *[Emergency
Management Agency]{.underline}*, *[Environmental Protection
Agency]{.underline}*, and *[Public Health Agency]{.underline}*. The
Technical Group will advise the Executive Group and Operations Group on
technical issues associated with recovery, and will coordinate with the
U.S. Army, the Regional Response Team and other organizations involved
in hazard assessment and remediation.

(*The model plan is couched in terms of these groups throughout. The mix
of agencies and officials appropriate for each group will vary by site.
If operating in an ICS-based environment, the recovery organization
structure may have different labels, but essentially the same functions
will be represented.*)

### 2.2.7 Plan Maintenance

This plan will be reviewed regularly and revised as necessary. The
*[CSEPP Planner or other designated staff person]{.underline}* will be
responsible for initiating the review. The plan will be circulated to
*[relevant organizations and officials]{.underline}* with a request for
comments every two years. The plan will also be reviewed when
significant demographic changes occur in the community being protected,
when the potential for an accident or incident changes, or when
capabilities to recover from a chemical event change. The revised plan
will be developed, reviewed, approved, and distributed using the same
protocols used for publication of the initial Recovery Plan.

### 2.2.8 Training

The *[Installation Commander]{.underline}* and *[Chief Executive or
Emergency Management Director(s)]{.underline}* will encourage all
agencies or departments to provide appropriate training for recovery
activities. Training may also be needed for volunteer organizations or
outside organizations that provide assistance through mutual aid
agreements. The recovery training program will be integrated with CSEPP
emergency response training and other emergency preparedness training
programs.

Training programs or modules pertaining to recovery operations include:

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(*List any training programs or modules available to staff that are
relevant to recovery operations. Examples include the following courses
and modules available through the Emergency Management Institute
\[EMI\]: E210 \[Recovery from Disaster\], E208 \[State Coordinating
Officer\], E288 \[State Donations Management\], E354 \[Basic Crisis
Counseling Grant Program\], E376 \[State Public Assistance Operations\],
E901 \[IEMC/All Hazards: Recovery and Mitigation\], E925 \[IEMC/State:
Response and Recovery\], G358 \[Evacuation and Re-entry Planning\],
G270.2 \[Federal Response Plan\], G270.4 \[Recovery from Disaster: The
Local Government Role\], G385 \[Disaster Response and Recovery
Operations\], and IS630 \[Introduction to Public Assistance Process\].
Further information about these and other emergency management training
courses can be obtained from the FEMA training resources portal
webpage*, <http://www.training.fema.gov/>.)

### 2.2.9 Exercises 

*[Name of installation]{.underline}* and *[names of
jurisdictions]{.underline}* will exercise the full range of their
capabilities for recovery from a chemical event, including this plan and
the personnel, equipment, and other resources required to implement it.
Recovery exercises will be evaluated, and the evaluation results will be
used as a basis for improving recovery capability. The format and
schedule of recovery exercises will be as follows:

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(*The recovery plan should be exercised periodically. A recovery
exercise can be conducted in conjunction with a CSEPP response exercise
or as a stand-alone activity. Parts of the recovery plan that should be
tested include hazard assessment, restricted and unrestricted reentry,
personnel protection, ingestion pathway protection, medical services,
social services, public information, claims and disaster assistance, and
environmental remediation.*)

\[blank page\]

## 2.3 HAZARD ASSESSMENT

After emergency protective actions have been implemented, depending on
the particular circumstances of the chemical event, there may be
residual hazards including residual chemical agent vapor, or in rare
cases aerosol deposition. Hazard assessment during recovery will
estimate the residual hazard.

### 2.3.1 Purpose

Assessment of the hazard to public health and safety in the affected
area will serve as a basis for allowing reentry by emergency teams and
for determining when unrestricted reentry can occur, whether ingestion
pathway protective measures are needed, and whether cleanup measures
will be required. Hazard Assessment will primarily be conducted by the
Army, but *[names of jurisdictions]{.underline}* will work with the Army
to ensure that hazard assessment resources will be directed where they
are most needed.

### 2.3.2 Concept of Operations

Hazard assessment for recovery involves determining the extent of
residual hazard posed by chemical agent, including localized residual
vapors as well as any contamination of water, soil, vegetation, crops,
animals, buildings, vehicles and other objects.

The Installation will gather data at the scene of the chemical event to
identify the agent involved and estimate the quantity of agent released
(if any) and how it was dispersed (e.g. whether there was fire or
explosion). Computer modeling will be used to estimate the areas
affected by vapor passage and by aerosol deposition, if any. Monitoring
and sampling will be used to check for residual agent in specific
locations.

The Army has trained personnel, equipment, and procedures for monitoring
and assessing agent contamination, including specific capability and
institutional experience in chemical agent detection and in operating
under conditions of actual or potential agent contamination.

The Technical Group will advise the Executive Group on what monitoring,
sampling and evaluation should be performed in order to assess the
possibility of residual hazard, assure public safety, and provide a
basis for decisions regarding reentry and recovery. The Executive Group
will coordinate among the organizations to provide for requested
monitoring, sampling and evaluation. Authority will be provided, as
needed, to allow Army personnel to enter private property to perform
monitoring and/or collect samples. Law enforcement personnel will be
tasked to accompany and assist monitoring teams where needed to ensure
access to private property.

There may be an initial urgent need to perform monitoring to support the
entry of emergency response teams into the restricted area to assist
persons who did not evacuate. If such assistance is needed in the
restricted area, real-time monitoring will be used to establish whether
the teams are properly protected for the environment in which they are
operating. Procedures for access to restricted areas are described in
section 2.4 below.

The U.S. EPA can provide assistance with hazard assessment through its
extensive network of contract resources for monitoring, sampling and
laboratory sample analysis. Assistance can be provided if requested by
the Army. Such assistance may require cooperation with the Army
regarding sample transport and provision of laboratory standard samples
(used for calibration of laboratory instruments) of chemical agents.

The *[State/local Environmental Protection Agency]{.underline}* has
teams that are appropriately trained, qualified and equipped to
accompany Army personnel performing monitoring and sampling. These
personnel will accompany Army technical teams to verify that correct
procedures are followed and that appropriate sample collection and chain
of custody protocols are observed.

(*Note, the last paragraph should be included only where a state or
local jurisdiction has the intent and resources to perform this
function. As stated in Appendix M to the CSEPP Planning Guidance,*

> *CSEPP Policy Paper No. 2 established program policy on environmental
> monitoring and sampling in the event of a chemical accident or
> incident. Pursuant to CSEPP policy, "\[t\]he Army, as the On-Scene
> Coordinator, will be responsible for sampling soil, air, and water to
> check for contamination by chemical agents." The policy paper allows
> State and/or local personnel to accompany the Army sampling teams as
> long as they are properly trained, qualified and equipped.*

*Alternatively or in addition, a jurisdiction could choose to develop an
independent capability to perform chemical agent hazard assessments.
That would involve training, equipping and qualifying personnel,
including backup teams if the intent is to operate in areas that have
not yet been cleared, and arranging for sample analysis at either Army
or other governmental or private laboratories.* *A listing of
agent-certified laboratories is provided in Annex G.*)

### 2.3.3 Monitoring and Sampling Priorities

After a chemical event, the Executive Group, with advice from the
Technical Group, will determine whether and where monitoring and
sampling will be performed, and will determine what areas should receive
priority based on the circumstances at the time.

To ensure that recovery proceeds as quickly as possible consistent with
public health and safety, off-post monitoring and sampling will be
prioritized to support (1) reentry to the restricted area to perform
vital missions; (2) allowing access to specific transportation
corridors, utilities and other critical infrastructures as soon as
possible, (3) progressive clearing of areas for unrestricted reentry,
and (4) providing assurance of safety to the public with respect to key
locations.

In general, unless monitoring is urgently needed in order to support a
vital mission, monitoring and sampling within off-post projected hazard
areas (areas where an agent plume has passed according to computer
projections) will begin approximately 24 hours after the release is
terminated. This time is needed to accommodate the organization and
equipping of sampling teams, to develop the specific priorities,
protocols, and locations for monitoring and sampling, and to set up the
infrastructure to deploy the teams safely. Allowing some time for the
dissipation of short term hazards will provide a truer picture of any
residual hazard of concern for reentry decisions. Also, it avoids
putting monitoring and sampling teams at unnecessary risk.

[Performance of Vital Missions in the Restricted Area]{.underline}

In a restricted area that has been evacuated (or relocated after an
initial sheltering period) there might be a need for reentry to perform
missions vital to public health and safety. For example, there might
persons who were unable to leave and require assistance, or an emergency
repair to collective protection equipment. First priority for monitoring
would be to accompany responders performing such missions. In support of
such missions, real-time monitoring for residual agent would be
performed to allow responders to operate in the area using appropriate
personal protective equipment (PPE) and to ensure that persons can be
evacuated without encountering an agent hazard.

[Clearing of Critical Infrastructure]{.underline}

The following transportation corridors and facilities are considered
critical for maintaining public health and safety. Restoring access by
responders and the public to these facilities is a 2nd priority for
monitoring.

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(*Some facilities and locations may merit priority for monitoring and
sampling, in order to minimize disruption of the community or to provide
services needed for public health and safety. Examples include:*

• *Major highways, railways, waterways or irrigation structures.*

• *Water intake or treatment plants.*

• *Medical facilities.*

• *Electric, gas, communication, or other utility structures that
require operation or maintenance by personnel.*

*The particular facilities or locations affected will depend on the
chemical event scenario.*)

[Progressive Clearing for Unrestricted Reentry]{.underline}

Monitoring will be performed in order to support the decision process
for unrestricted reentry to areas that were restricted during the
initial set of emergency protective actions. This will be performed in a
phased manner to allow those areas not at risk to be quickly opened for
reentry, and to concentrate monitoring resources where results will be
the most useful for decision-making.

Initial hazard predictions and emergency protective actions will likely
be based on some sort of assumption as to the amount of chemical
released. For events associated with agent operations, the maximum
credible event (MCE) for the daily workplan would be used. For events
not associated with active operations, such as an event detected during
non-duty hours, a standard "non-operational event scenario" or other
default assumption would be used. As installation personnel respond to
the event, they will be better able to determine whether a release
actually occurred and its true source term. Once that is determined, a
new hazard assessment will be performed. It is expected that in most
cases, the new hazard assessment will result in a revised source term
that is smaller than the initial, assumption-based source term. That in
turn will lead to a smaller projected hazard area.[^2] In light of these
probabilities, four distinct zones can be identified for purposes of
reentry decisions, monitoring and sampling:

> [Reentry Area 1]{.underline} ‑ Areas outside of the initial projected
> hazard area, that were evacuated because they were part of a
> protective action area impacted by the projected hazard area.
>
> [Reentry Area 2]{.underline} ‑ Areas inside the initial projected
> hazard area, but outside of the revised projected hazard area that is
> determined after the post‑accident assessment.
>
> [Reentry Area 3]{.underline} ‑ Areas inside the revised projected
> hazard area.
>
> [Reentry Area 4]{.underline} ‑ Areas that are potentially contaminated
> with aerosol deposition. This area can only exist in some very
> specific scenarios and will likely be quite small as compared with the
> area where a vapor plume might have traversed.

The four areas are illustrated in a series of figures beginning on the
next page. The figures depict a hypothetical chemical depot and the
community near the depot, divided into a number of predesignated
protective action areas or "zones." (*In other words, these are the
units of area that would be directed to evacuate or take shelter in an
emergency. In local plans they may be referred to as "zones,"
"subzones," "sectors," or some other term. They are generally depicted
on public information materials with letter designations such as A1, B2
and so on*.)

**Figure 1: Initial and Revised Plume Estimates and Safety Envelopes**

Figure 1 shows an example of an initial and revised plume projection and
their associated hazard areas. The figure depicts irregular plumes and
safety envelopes as would be projected using the D2-Puff^TM^ software.

**Figure 2: Initial Evacuation or Shelter Area**

Figure 2 above shows the area that would be evacuated (or sheltered in
place) based on the example hazard area. The shaded area includes each
predesignated protective action area that is touched by the projected
hazard area (safety envelope).

**Figure 3: Reentry Area 1**

Figure 3 above shows Reentry Area 1. Reentry Area 1 represents an area
that, even according to the initial, conservative hazard estimate, was
not exposed to chemical agent. It is the area outside of the initial
projected hazard area but within the predesignated protective action
areas that the hazard area touched. Protective actions were applied to
this area because of the predesignated protective action area structure,
but at no time was agent projected to have affected this area. Reentry
Area 1 can be cleared for unrestricted reentry as soon as the hazard has
been contained on the installation.[^3] No monitoring of Reentry Area 1
is required, because agent was never projected to enter the area.

**Figure 4: Reentry Area 2**

Figure 4 above shows Reentry Area 2, which is the area inside the
initial projected hazard area (safety envelope) but outside of the
revised hazard area. The logical assumption is that Reentry Area 2 is
also safe to enter without monitoring, since based on the updated source
term information, no hazard is projected in that area. However, since
the public may have been told initially that agent may have entered this
area, some further actions may be appropriate to provide assurance that
it is safe to reenter. Selected sampling and analysis may also be needed
to offset concerns about perceived damages, especially to agricultural
resources.

**Figure 5: Reentry Area 3**

Figure 5 shows Reentry Area 3. That is the area within the revised
projected hazard area. Based on modeling with D2-Puff^TM^, that is the
area where vapor hazards might have been present before the plume
dissipated. Prior to unrestricted reentry, selective air monitoring will
be performed within this area in locations where agent vapors may have
lingered, e.g., inside structures. In addition, soil, water, vegetation
and other surface material monitoring and sampling may be performed
(even if model projections do not suggest the possibility of agent
deposition) to allay concerns over public safety and offset perceived
damage to agricultural products and other property in the area.

**Figure 6: Reentry Areas 3 and 4 in Deposition Scenario**

Figure 6 shows Reentry Areas 3 and 4 for a scenario involving the
possibility of aerosol deposition. Reentry Area 4 is the area that is
potentially contaminated with deposited agent. This area only exists in
specific scenarios involving a fire affecting explosively-configured HD
or VX. Note that the area of potential aerosol deposition is expected to
be relatively small and close to the source. When it is determined that
there may be such deposition, a more comprehensive program of air, soil,
surface, and water sampling may be required to ensure that the public
can safely return to the area. A long‑term restoration effort may be
required in the affected area.

In order to clear the largest area for unrestricted reentry in the least
possible time, generally the priority for monitoring and sampling will
proceed from the outside in, i.e. Reentry Area 2, then 3, then 4. In
some cases it may be possible to clear both Reentry Areas 2 and 3 by
monitoring in Area 2.

The Technical Group will coordinate with Army personnel to determine
priority locations for monitoring based on where residual hazards would
most likely be found under the circumstances at the time.

[Clearing of Other Priority Locations]{.underline}

In conjunction with progressing clearing of areas for unrestricted
reentry, the following locations will be specifically monitored in order
confirm they are safe:

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(*It may be desirable to list particular types of facilities to be
specifically monitored. Such a list will depend on local circumstances
and priorities. The particular facilities or locations affected will
depend on the chemical event scenario and the projected hazard area.
Examples of the types of facilities that might be on such a list
include:*

• *Hospitals and nursing homes.*

• *Schools and daycare centers.*

• *Residential areas.*

• *Major businesses.*

• *Farms and food production or storage facilities.*

• *Water treatment facilities.*)

### 2.3.4 Monitoring and Sampling Resources

The following monitoring and sampling resources are expected to be
available to support recovery operations:

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(*The above should be completed based on the resources available to the
installation. Air sampling assets that are the most immediately
available are already at the chemical storage sites. Each installation
has several mobile Real Time Analytical Platforms (RTAPs), with trained
operators, that can be deployed off-post within 2-8 hours after a
chemical accident. Some sites have agreements with other chemical
storage sites to borrow additional RTAPs and RTAP operators in an
emergency. These can be deployed to the accident site within 12-24 hours
after they are requested, and can be operational in the field 4-8 hours
after arrival. In addition, the Army Service Response Force can arrange
for several RTAPs and operators to relocate to the accident site within
approximately 24 to 48 hours. When deployed, each RTAP can provide low
level near-real-time air sampling results for a specific location at a
specific time at the rate of approximately 4 samples per hour. The
actual output rate depends on the travel time between air sampling
locations, crew change and equipment maintenance requirements, weather,
availability of lighting during hours of darkness, the adequacy of
communications links between field teams and hazard analysts, and
whether the efficiency of the instruments and the work-rest cycles of
the operators will be depreciated by working in a contaminated
environment. The utility of the results depends in part on the
opportunity for access to locations that are private property and/or
difficult to reach cross-country, and limitations on deployment to areas
where other hazards might be a consideration. Local planners should
consult with chemical storage site officials to determine the actual
capability of the Army to sample air off-post should an accident occur
at that site. All things considered, it might be possible to sustain air
sampling operations off-post that produce results at the rate of 12 to
24 discrete locations per hour for an indefinite period after the first
day.*

*There are other instruments (e.g., hand-held monitors and detectors)
capable of detecting hazardous vapors, but these are either less
sensitive or take longer to obtain results, and might require laboratory
support. Some of these instruments can be useful in ensuring that first
responders avoid areas where their PPE will not protect them, but are
less useful in deciding if areas or structures are suitable for
unrestricted occupancy. There is the possibility that new technologies
have recently been incorporated into air sampling devices that will
offer capabilities better than described above or in the CSEPP
Monitoring IPT Report, but none have been accredited for CSEPP use as of
the date of this workbook.*

*Surface sampling (to include water) involves laboratory analysis. This
introduces additional logistical operations that will delay results, as
discussed in the CSEPP Monitoring IPT Report. On the other hand, there
are many technicians around the country who are trained and can be
equipped to take samples for laboratory analysis, and a number of
laboratories that can process the samples. A listing of laboratories
capable of handling chemical agent samples is provided in Annex G. As
with planning for air sampling, recovery planners should consult with
the Army about the local output rate for surface samples collected by
Army responders or by operators from other organizations (e.g., U.S.
EPA) deployed at the request of the Federal On-Scene Coordinator. All
things considered, it is reasonable to expect to sustain surface
sampling operations at the rate of two or three dozen discrete locations
per hour for an indefinite period after the first day, but there will
probably be an additional 24 to 72 hour lag time from the collection of
a sample to the completion of the laboratory analysis. Details of the
sample processing protocols, such as elaborate chain of custody
procedures, split sampling, and formal laboratory QA/QC, might increase
the lag time by an additional 24 to 48 hours. The effective rate of
sample processing will depend on the throughput rate at each laboratory,
which in turn will depend on a number of factors including equipment
available, need to reconfigure equipment, the medium of the samples
being processed, the priority given to processing these samples, and
other factors. As with air sampling, the rate that surface samples are
collected can be affected by weather, visibility, communications
capabilities, agent contamination, other hazards, and access to sample
sites. Moving portable laboratories to the field can reduce lag time to
process samples substantially, but there probably are only a handful of
these that are deployable to an accident site in less than a week.*

*Note that the CSEPP Monitoring IPT Report calls for development of a
site-specific monitoring plan: "It is essential that at each storage
location a coordinated off-post monitoring plan be developed that
addresses actions to be taken in the event a chemical event occurs.
Coordination and applicable agreements must include the Army Chemical
Activities, the counties, the state, and federal agencies. The agreement
should define the expected equipment, procedures, and coordination. It
should separate response requirements from recovery requirements."
\[CSEPP Monitoring IPT Report p. iv.\] The Monitoring IPT Report
discusses equipment requirements for the types of monitoring missions
outlined in the Workbook and provides a sample monitoring plan in an
appendix.*)

### 2.3.5 Responsibilities by Position/Organization

[Installation Commander]{.underline}

1\. Prior to any emergency, work with off-post jurisdictions that desire
to have personnel accompany Army monitoring and sampling teams, per the
provisions of CSEPP Policy Paper #2.

2\. In a recovery situation, ensure that data from on-post monitoring
and sampling is shared with off-post technical and emergency management
staff. In events with a possible criminal aspect or other security
concern, data will be shared only to the extent compatible with section
11-5.b of Army Regulation (AR) 50-6.

3\. Work with the Technical Group and the Executive Group to develop a
priority scheme for hazard assessment. Secure resources through Army
channels to perform monitoring and sampling to support off-post
protective action decision making.

4\. Work with the Technical Group and the Executive Group to assist
off-post decision makers in defining areas for unrestricted reentry and
relaxing protective actions as appropriate.

5\. Coordinate with state/local law enforcement agencies to obtain
access to private areas for performing monitoring and sampling, as
necessary.

6\. Direct and supervise implementation of the Monitoring and Sampling
Plan.

*[Chief Executive or Emergency Management Director]{.underline}*

1\. Work with the Technical Group, the Executive Group, the Army, and
other involved jurisdictions to develop a priority scheme for hazard
assessment.

2\. Work with the Technical Group, the Executive Group, the Army, and
other involved jurisdictions to define areas for unrestricted reentry
and relax protective actions as appropriate.

3\. Request the Army to provide monitoring and sampling to support
reentry to evacuated areas.

4\. Coordinate between the Army and state/local law enforcement agencies
to obtain access to private areas for performing monitoring and
sampling, as necessary.

5\. Direct implementation of the Monitoring and Sampling Plan.

*[Primary Technical Organization: Environmental Agency]{.underline}*

1\. Work with the Technical Group to define areas for unrestricted
reentry and develop recommendations on relaxing protective actions.

2\. Work with the Technical Group to develop priorities for monitoring
and sampling and recommend resources to be requested from the Army.

3\. Work with the Technical Group to implement the Monitoring and
Sampling Plan.

4\. Assign personnel to accompany/monitor/assist Army teams in
performing monitoring and sample collection. (*Provided this function
has been incorporated into planning and there are teams with the
appropriate qualifications, training and equipment to operate in the
target environment. See section 2.4 directly below*.)

*[Law Enforcement]{.underline}*

1\. Work with the Army to ensure that monitoring and sampling teams have
access to locations where they need to perform monitoring and sampling.

*[Hazardous Materials Team]{.underline}*

1\. Work with the Army and environmental agencies to support entry team
decon, as needed.

### 2.3.6 ICS -- Based Responsibilities 

*[Incident Command]{.underline}*

1\. Ensure that data from on-post monitoring and sampling is shared with
off-post technical and emergency management staff. In events with a
possible criminal aspect or other security concern, data will be shared
only to the extent compatible with section 11-5.b of AR 50-6.

2\. Work with Command staff, Planning Section and Operations Section to
develop a priority scheme for hazard assessment. Secure resources
through Army channels to perform monitoring and sampling to support
off-post protective action decision making.

3\. Work with Command staff, Planning Section and Operations section to
define areas for unrestricted reentry and relax protective actions as
appropriate.

4\. Coordinate with state/local law enforcement agencies to obtain
access to private areas to perform monitoring and sampling, as
necessary.

5\. Direct and supervise implementation of the Monitoring and Sampling
Plan.

*[Planning Section]{.underline}*

1\. Define areas for unrestricted reentry and develop recommendations on
relaxing protective actions.

2\. Develop priorities for monitoring and sampling and list of resource
needs for monitoring and sampling. Coordinate resource needs through
Logistics Section. The Army will be the primary supplier for monitoring
and sampling services.

3\. Develop a Monitoring and Sampling Plan.

4\. Work with the Operations Section to implement the Monitoring and
Sampling Plan.

*[Operations Section]{.underline}*

1\. Assign personnel to accompany/monitor/assist Army teams in
performing monitoring and sample collection. (*Provided this function
has been incorporated into planning and there are teams with the
appropriate qualifications, training and equipment to operate in the
target environment. See section 2.4 below*.)

2\. Ensure that monitoring and sampling teams have access to locations
where they need to perform monitoring and sampling.

3\. Work with the Army and environmental agencies to support entry team
decon, as needed.

*[Logistics Section]{.underline}*

1\. Provide resources to support monitoring and sampling teams (e.g.
vehicles, communications, shipping, as needed).

*[Finance/Administration]{.underline}*

1\. Track contracts and costs for any contract-support sampling teams or
analytical laboratories used in the course of hazard assessment.

## 2.4 ACCESS TO RESTRICTED AREAS

### 2.4.1 Purpose

Access to evacuated areas will be controlled until they are cleared for
unrestricted reentry, to prevent possible exposure of the public to
residual hazards within the area. Emergency workers and others who must
enter restricted areas will be protected from potential exposure to
residual hazards through access management and use of personal
protective equipment (PPE). The *[Incident Commander]{.underline}* will
determine priorities for access to restricted areas and will ensure that
emergency teams entering the restricted area are using appropriate PPE
and following appropriate safety procedures.

### 2.4.2 Assumptions

• Control of access to evacuated areas will have been initiated during
emergency response.

• There may be some specific missions requiring immediate access to
restricted areas to preserve human life and health.

• There will be pressure from displaced residents and businesspersons
for quick return to the affected area.

• There will be pressure from news organizations for access to the
restricted area.

• Monitoring and evaluation to confirm the safety of evacuated areas
will likely proceed in phases and if there were significant chemical
agent concentrations off-post, some areas will take days to weeks to
clear.

### 2.4.3 Concept of Operations

Access to affected areas will be controlled to protect public health and
safety, to secure the area, and to allow monitoring, sampling, recovery
and cleanup operations to proceed. Access and reentry will be
coordinated among jurisdictions and agencies to provide continuing,
effective perimeter control. Information will be provided to the public
as to the reason for restricting the area and progress of efforts to
clear it for unrestricted reentry.

It may be necessary for emergency workers and other persons to enter the
restricted zone, prior to the area being cleared for unrestricted
reentry. The risk of exposure to chemical agent will be minimized by
eliminating unnecessary tasks or practices that carry such a risk. When
such risk is unavoidable, exposure will be minimized by use of
protective equipment and clothing combined with monitoring and the
availability of medical intervention as required. Entry to restricted
areas will be recorded and tracked to minimize and maintain a record of
risk exposure.

(*It should be noted that the Army has personnel trained and equipped to
operate in areas contaminated with chemical agent. Extensive Army
resources will be available to the Service Response Force Commander
responding to a chemical event. It may be possible to arrange to have
Army personnel perform necessary tasks within the restricted area, as a
substitute for local or state personnel, depending on time available and
the types of duties to be performed. Alternatively, it may be necessary
to consider what plans and policies are needed to address protection of:
(a) first responders, including personnel from other jurisdictions who
may be assisting through a mutual aid agreement; and (b) persons needed
to maintain, repair or operate critical infrastructure -- for example to
shut off the gas supply, operate a water filtration plant, or repair
electrical lines.*)

### 2.4.4 Tasks and Personnel in Restricted Areas

The following tasks and personnel may be needed in restricted areas:

[Tasks]{.underline}

> • Search and rescue / evacuation assistance.
>
> • Law enforcement.
>
> • Fire fighting.
>
> • Infrastructure repair, maintenance or operation.
>
> • Monitoring and sampling for contamination.
>
> • Decontamination and cleanup.
>
> • Traffic and access control.

[Personnel]{.underline}

> • Fire department.
>
> • Emergency medical service.
>
> • Law enforcement.
>
> • Public works department.
>
> • Public health department.
>
> • Federal agency -- e g. EPA, USDA.
>
> • Utility companies.

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(*Consider the above list and edit as needed for local circumstances.
Are there critical facilities within the IRZ that require operators or
regular maintenance? Note that access to restricted areas may require
use of personal protective equipment, which in turn requires training,
qualification, equipment fitting, and logistical arrangements in advance
of an emergency.*)

### 2.4.5 Procedures for Access and Personnel Protection

[Safety Coordinator]{.underline}

*[Name of position]{.underline}* will be responsible for coordinating
and implementing safety measures, including approving entry into
restricted areas, establishing personnel protection procedures and
controls, and ensuring use of appropriate protective equipment.

(*To ensure protection and tracking of persons working in the risk area,
it is recommended to delegate oversight of this function to one
position, such as the chief executive, health officer, or a designated
safety officer.*)

[Access Protocol]{.underline}

To protect public health and safety, access to the restricted area will
be prohibited, except through the following protocol:

\(1\) Access will be allowed by permission of the Incident Commander,
with the concurrence of the Safety Coordinator.

\(2\) Access will be allowed at designated entry points only. Entry
points will be staffed by *[designated agency]{.underline}*. Entry may
be limited to particular routes and locations within the restricted
area. Duration of missions in the restricted area may likewise be
limited.

\(3\) Entry point personnel will log each entry to the restricted area,
including reason for entry, level of PPE worn and monitoring equipment
used, and entrance/exit times for all persons entering the restricted
area. Records will be retained of all entries.

\(4\) Entry point personnel will check that each person entering the
restricted area has appropriate monitoring support, as needed; PPE and
logistical support, as needed; access to communications for requesting
assistance; and an estimated exit time.

\(5\) Entry point personnel will check for documentation that each
person using PPE in the restricted area is appropriately trained and
qualified on the equipment.

\(6\) Entry point personnel will be prepared to perform expedient
decontamination and emergency first aid procedures for persons
presenting symptoms of agent exposure.

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(*Consider establishing a formal procedure for entering a risk area,
addressing the points listed above. Declaration of a State of Emergency
at the local or state level will provide authority for controlling
access*.)

[Use of PPE]{.underline}

The best available equipment and training will be used to protect
personnel from chemical agent hazards. Equipment to be used, personnel
qualifications, training programs, and procedures for entry into
possible hazard areas are described in Attachment \_\_\_.
(*CSEPP-approved protective equipment is listed in Annex E.*)

Emergency worker PPE will be matched to the level of hazard as
determined by computer model projections and on-the-spot monitoring.
Only agent-approved Level A gear and self-contained breathing apparatus
will be used where immediately dangerous to life and health (IDLH)
conditions are projected or are detected through monitoring.
Air-purifying respirators and other Level C gear will be used in areas
where agent is below IDLH levels as determined by on-the-spot
monitoring.

Use of PPE will be limited to individuals who are medically qualified
and trained on the specific equipment to be used.

(*The specific equipment, training and procedures to be used should be
provided in an attachment to the Recovery Plan. OSHA regulations have
extensive requirements for emergency personnel entering an area of
unknown hazard, including use of PPE, use of monitoring devices,
availability of standby personnel to perform rescue, and others.*

*CSEPP-specific guidance and information on protective equipment,
monitoring, and procedures to support entry to hazard areas may be found
in the CSEPP Planning Guidance, Appendix H \[1996\]; the CSEPP Off-Post
Monitoring IPT Report \[December 1998\]; and the report "How Do I Know?
A Guide to the Selection of Personal Protective Equipment for Use in
Responding to a Release of Chemical Warfare Agents," ORNL/TM-13343,
Cheri Bandy Foust \[May 1999\].* )

### 2.4.6 Responsibilities by Position/Organization

[Installation Commander]{.underline}

1\. Ensure that installation personnel performing emergency-related
tasks off-post coordinate with civilian authorities with respect to
procedures for access to restricted areas.

*[Chief Executive or Emergency Management Director]{.underline}*

1\. Oversee control of access to restricted area and ensure that public
is made aware of the restrictions, the reasons for them, and progress on
clearing the area for unrestricted reentry.

2\. Determine or review the types of personnel and tasks that require
reentry into restricted areas. Approve policies for permitting emergency
workers to enter risk areas.

3\. Ensure that appropriate PPE, monitoring equipment and procedures are
used. Ensure that all persons using PPE are qualified to use the
equipment.

4\. Designate responsibility for personnel protection and other related
or support functions as appropriate among agencies and staff.

5\. Ensure that policies and agreements are in place for the protection
of any personnel from other jurisdictions, responding under mutual aid,
who may enter the risk area.

6\. Ensure that appropriate lawful written orders about the use of force
are given to law enforcement officers at access control points.
(*Ideally, these instructions would be prepared in advance and
incorporated into the training of law enforcement officers*.)

*[Primary Access Control Organization: Law Enforcement]{.underline}*

1\. Control access to restricted area through staffed access control
points, barricades and other methods. Coordinate with supporting
organizations to provide staff and resources for continuing perimeter
control.

2\. Operate entry points, with assistance from other agencies.

*[Primary Technical Organization: Health Department or Safety
Officer]{.underline}*

1\. Advise officials on personnel protection policy, including
applicable occupational health regulations and guidance.

2\. Work with emergency management staff (and other organizations as
appropriate) in evaluating and selecting equipment and facilities to be
procured, including monitoring equipment, protective clothing and
equipment, and first aid and decontamination kits.

3\. Work with emergency management staff (and other organizations as
appropriate) to ensure that appropriate procedures are followed for
equipment inventory, testing, and maintenance.

4\. Develop and provide appropriate procedures and training on the use
of equipment, monitoring, first aid, and other aspects of personnel
protection.

5\. Develop protocol and procedures for entry and exit of personnel to
risk areas (*include in annex to the recovery plan*).

6\. Work with outside organizations (*e.g., the Army, OSHA*) to
continually assess and improve the personnel protection program.

### 2.4.7 ICS -- Based Responsibilities 

*[Incident Command and Safety Officer]{.underline}*

1\. Oversee control of access to restricted area and ensure that public
is made aware of the restrictions, the reasons for them, and progress on
clearing the area for unrestricted reentry.

2\. Determine or review the types of personnel and tasks that require
reentry into restricted areas. Approve policies for permitting emergency
workers to enter risk areas.

3\. Ensure that appropriate PPE, monitoring equipment and procedures are
used. Ensure that all persons using PPE are qualified to use the
equipment.

4\. Designate responsibility for personnel protection and other related
or support functions as appropriate among agencies and staff.

5\. Ensure that appropriate protective equipment and clothing is
available.

6\. Ensure that policies and agreements are in place for the protection
of any personnel from other jurisdictions, responding under mutual aid,
who may enter the risk area.

7\. Ensure that appropriate lawful written orders about the use of force
(especially deadly force) to control access to restricted areas are
given to law enforcement officers at access control points.

*[Planning Section]{.underline}*

1\. Obtain information about the degree of health threat in restricted
areas. Advise Incident Command and Operations about health threats and
appropriate monitoring and PPE to ensure worker safety.

2\. Coordinate Army resources (*and any others available*) to perform
hazard monitoring in support of worker entry to restricted areas.

3\. Advise Incident Command and Operations on use of equipment,
monitoring, first aid, and other aspects of personnel protection.

4\. Advise Incident Command and Operations on protocol and procedures
for entry and exit of personnel to restricted areas.

5\. Advise Incident Command and Operations on public safety-related
missions that may need to be performed in restricted areas. (*For
example, fire suppression or necessary maintenance or repairs to
utilities.*)

*[Operations Section]{.underline}*

1\. Control access to restricted area through staffed access control
points, barricades and other methods.

2\. Perform necessary public safety-related missions in restricted
areas.

3\. Implement appropriate worker safety procedures for personnel
entering restricted areas, including hazard awareness, use of
appropriate PPE, back-up teams, and perimeter check-in and check-out
procedures.

*[Logistics Section]{.underline}*

1\. Ensure that medical services are available for emergency workers,
including any who may suffer toxic exposure, heat injury, or other
injury while operating in restricted areas.

2\. Coordinate with supporting organizations to provide staff and
resources, as needed, for continuing perimeter control.

*[Finance/Administration]{.underline}*

1\. Track costs associated with access control, including cost of
perimeter control, medical care, etc.

2\. Ensure that records are maintained of what areas were restricted;
when the restrictions were imposed and lifted; and entry of emergency
workers into restricted areas.

\[blank page\]

## 2.5 INGESTION PATHWAY PROTECTION

### 2.5.1 Purpose

During a severe chemical event, chemical agent might contaminate food or
water supplies off-post so as to pose a danger to public health through
ingestion. The primary purpose of ingestion pathway protection is to
identify and control potential hazards to public health through the
ingestion pathway. A secondary purpose is to assure the integrity of
food supplies and allow uncontaminated products to be sold and consumed.
Ingestion pathway protection will be directed by *[name of
jurisdiction]{.underline}*.

### 2.5.2 Concept of Operations

Ingestion exposure could occur if chemical agent were deposited on or
absorbed into stored food, crops, food animals, or food gathered from
the wild. Ingestion exposure could also result from contamination of
food production, storage, processing, or retailing facilities.

Ingestion exposure is considered a hazard mainly through the direct
ingestion of items on which agent has been deposited in the form of
aerosol droplets. It is also possible that harmful amounts of agent
would be absorbed by foods stored in the open in areas subject to heavy
concentrations of agent vapor for long periods. Foods that have been
subject to possible deposition or heavy concentrations of agent vapor
may be sampled for contamination and/or may be embargoed and destroyed.

Ingestion exposure through contamination of drinking water supplies is
considered highly unlikely due to dilution by large volumes of water and
the tendency of the agents to break down in water (hydrolize). However,
some sampling and analysis of drinking water may be appropriate to
confirm that it is safe.

Ingestion exposure through bioaccumulation of agent (accumulation
through the food chain) is also considered highly unlikely.

Ingestion pathway protection will involve:

> • Identification of ingestion pathway items that might be affected.
>
> • Assessment of the actual or potential level of contamination
> present.
>
> • Protective action decision making and implementation.

Ingestion pathway hazards will be assessed and controlled by:

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(*Responsibility may lie at the federal or state level and the agencies
involved may vary from state to state. Generally drinking water will be
the responsibility of the state environmental protection agency, and
food safety will be the responsibility of state agricultural and health
departments.*

*Under state emergency management laws, a declaration of emergency gives
the Governor (and usually local chief executives) special powers to
embargo food and other goods and prevent their transport and sale.*

*Studies indicate that ingestion pathway contamination is a concern only
in areas where there has been aerosol deposition of agent, or else a
lengthy exposure to strong concentrations of agent vapor. Both
circumstances would require an unusually severe chemical event and
concern for ingestion pathway contamination would be limited to areas
very close to the installation. In the case of lengthy exposure to
strong concentrations of agent vapor, it is possible that exposed food
items, especially absorbent items such as bread, might absorb enough
agent to be harmful, similarly to the way non-food absorbent items such
as drapes and upholstery might.*

*Contamination of drinking water supplies, whether from groundwater or
surface water, is considered unlikely due to the effects of dilution and
the tendency of the agents to hydrolize in contact with water.*

*A discussion of the potential for agent exposure through contamination
of groundwater or surface water, bioaccumulation, and other means may be
found in the report, "Derivation of Health-based Environmental Screening
Levels For Chemical Warfare Agents: A Technical Evaluation" (March 1999)
prepared by the U.S. Army Center for Health Promotion and Preventive
Medicine (USACHPPM), Aberdeen Proving Ground, Maryland.*

*If a chemical event occurs and there is concern over contamination of
food items, depending on the circumstances it may be more practical and
less expensive to simply destroy the suspect food rather than test it to
establish its safety.*)

### 2.5.3 Identification of Potential Ingestion Pathway Concerns

The following types of resources and facilities are potential concerns
for ingestion pathway contamination within the IRZ:

[Residential]{.underline}

• Food stored in open containers.

• Home gardens, vineyards, fruit trees.

[Retail Food, Beverage & Drug Sales and Service]{.underline}

• Grocery stores, drug stores, convenience stores.

• Restaurants and catering services.

• Institutions with meal service (e.g. schools, nursing homes,
hospitals).

[Wholesale Food & Beverage Sales and Service]{.underline}

• Food, beverage and drug storage and processing facilities (e.g.,
canneries, dairies, stockyards, warehouses).

• Facilities for manufacturing or storing food packaging, additives, or
other materials that may come into contact with food or beverages.

[Agricultural and Food and Beverage Production Facilities]{.underline}

• Farms, vineyards and orchards with crops grown for direct human
consumption (e.g., fruits and vegetables, grain, beans, oilseed,
tobacco, herbs and spices).

• Farms, ranches and feedlots raising animals for human consumption.

• Fish farms.

• Dairies.

• Egg producers.

• Honey producers.

• Breweries, distilleries, vintners, bottling plants.

[Articles harvested from the wild]{.underline}

• Game fish and animals, wild fruit, mushrooms, honey, maple syrup,
herbs.

[Water Supplies]{.underline}

• Public water supplies.

• Private water supplies.

(*A key element of ingestion pathway protective planning is identifying
ways that chemical agent contamination could enter the food chain. The
above list is intended as a starting point for identifying the types of
resources and facilities that might be of concern. Some or all of these
may be applicable to a particular site, and there may be other types not
represented on this list.*

*Identifying categories such as those listed above is preliminary to
identifying the actual list of businesses, farms and so on. Ideally,
such a list would be compiled ahead of time and updated periodically.
However, turnover in restaurants, stores, and so on may render that
impractical.*

*Whether compiling a list ahead of time or after a chemical event, the
following sources may be of use:*

• *The site-specific Environmental Impact Statement prepared for the
Chemical Stockpile Demilitarization Program.*

• *Databases compiled by regulatory agencies such as the state Public
Health Service and Agricultural Extension Service.*

• *Industry association lists.*

• *Yellow page telephone directories and Internet directories*.)

### 2.5.4 Authority for Ingestion Pathway Protection

Authority for ingestion pathway protective actions comes from multiple
sources at the federal and state level:

• Federal food safety and inspection laws.

• The federal Safe Drinking Water Act.

• *[State drinking water and food safety laws]{.underline}*.

• *[State Emergency Management Statute]{.underline}*.

*A number of statutes provide authority for protection of food, drugs,
and water supplies against public health hazards. At the federal level,
the U.S. Department of Agriculture (USDA) and the Food and Drug
Administration (FDA) within the Department of Health and Human Services
(DHHS) are primarily responsible for food safety. The USDA inspects
meat, poultry, and associated facilities such as stockyards and packing
houses. Products may be detained, seized, and condemned if they are
found to be "adulterated," which is broadly defined as containing ". . .
any poisonous or deleterious substance which may render \[them\]
injurious to health . . . ." (9 CFR § 301.2(c)) Any animal that has died
other than by slaughter is considered adulterated, as are animals
suffering symptoms of nervous system disorder, such as lack of muscular
coordination (9 CFR §§ 301.2(c),(y)). Meat, as defined in the
regulations, includes products derived from cattle, sheep, swine, goats,
horses, mules, and other equines. Poultry includes ". . . any
domesticated bird (chickens, turkeys, ducks, geese, or guineas) . . . ."
(9 CFR  §381.1) The regulations also provide for enforcement actions
against livestock suspected of having biological residues "of a harmful
substance that will render them unfit for human consumption."
(9 CFR § 309.16) The USDA cooperates with States in administering the
inspection program. Most states have USDA-approved inspection programs,
so that inspections are performed primarily by state personnel.*

*The FDA is broadly charged under the Food, Drug, and Cosmetic Act with
protecting the public against adulterated foods, drugs, and cosmetics.
(21 U.S.C. §§ 321, 331) The statute provides enforcement mechanisms,
including issuance of injunctions against performing prohibited acts
(e.g., shipping or selling adulterated items); however, the agency must
obtain a court order for those. The FDA often acts by requesting that
the owners of suspect items act voluntarily to withhold or withdraw them
from market; implicit in such a request is the possibility of
enforcement action if it is not complied with (21 CFR § 7). The FDA has
cooperative programs with states to administer inspections of retail
food sellers, milk, and shellfish.*

*Authority over certain foods may stem only from state emergency powers;
for example, food in peoples' homes and gardens. Such items are beyond
the regulatory reach of the federally authorized food safety programs.*)

### 2.5.5 Ingestion Pathway Exposure Hazard Assessment

The Technical Group will determine possible ingestion pathway hazards
and will make recommendations to the Executive Group for protective
actions and use of sampling resources, including:

• What areas may be affected by ingestion pathway contamination, based
on the best available information as to the type, amount and
circumstances of chemical agent releases.

• What protective actions should be issued immediately to protect public
health and safety and the integrity of food and water supplies.

• Locations and media to be sampled to assess ingestion pathway hazards.

• Protective actions to be added or relaxed based on analysis of
samples.

Proposed or final standards for agent exposure (chronic reference
doses), drinking water, soil, and other media have been published by
military and civilian authorities. In developing recommendations for
ingestion pathway protection, the Technical Group will use final
civilian standards where applicable, and will review proposed civilian
standards and military standards for relevance. (*Current final and
proposed standards are summarized in Annex F*.)

### 2.5.6 Ingestion Pathway Protective Actions

The following protective actions may be used, where applicable, to
protect public health and safety and the integrity of food and water
supplies:

• Advising the general population not to eat food from gardens or that
was stored in the open or gathered from the wild in certain areas.

• Advising the general population not to drink water from certain
private or public water supplies.

• Advising those with farm animals to place the animals on stored feed
and covered water (if not in an evacuated or sheltered area).

• Temporary closure of food, beverage and drug processing or production
facilities.

• Temporary closure of drinking water intake facilities.

• Temporary embargo preventing food, beverages and drugs from being
shipped from area.

• Quarantine of foods, beverages and drugs pending determination as to
further action.

• Condemnation and disposal of certain foods, beverages and drugs.

### 2.5.7 Responsibilities by Position/Organization

[Installation Commander]{.underline}

1\. Coordinate with *[the Chief Executive or Emergency Management
Director]{.underline}* to secure resources for sampling and analysis to
support ingestion pathway decision making. Oversee implementation of
sampling and analysis effort.

*[Chief Executive or Emergency Management Director]{.underline}*

1\. In advance of any emergency, develop information on water, food,
beverage and drug resources within the IRZ that are potentially at risk
of contamination by chemical agent.

2\. In advance of any emergency, coordinate planning among state and
federal agencies with responsibilities for ingestion pathway protection.
Negotiate formal agreements as needed with respect to allocation of
responsibilities among agencies.

3\. During recovery from a chemical event, make protective action
decisions relating to the ingestion exposure pathway, in coordination
with the Executive Group and with advice from the Technical Group. May
include measures such as shutoff of water utilities, quarantine or
inspection of consumables, and provision of alternate water and food
supplies to displaced persons.

4\. Coordinate activities to ensure effective implementation of
ingestion pathway protective actions.

5\. Coordinate ingestion exposure pathway protection activities with
public information personnel to ensure the public has necessary
information relating to ingestion pathway hazards.

6\. Coordinate with the Army and other organizations to secure resources
for sampling and analysis to support ingestion pathway decision making.

7\. Ensure that records are maintained of decisions and actions taken on
ingestion exposure pathway protection.

*[Primary Implementing Organization: Agriculture or Public Health
Department]{.underline}*

1\. Assemble information on local water supplies, food and drug
production, processing and distribution facilities, and other
information as appropriate in advance, to provide a basis for
determining and implementing protective actions after a chemical event.

2\. During recovery from an emergency, advise the Executive Group
regarding appropriate ingestion pathway protective actions.

3\. Coordinate with organizations responsible for hazard assessment.
Identify monitoring and sampling needed to support ingestion pathway
protective action decision making. Ensure that monitoring and sampling
to support ingestion pathway decision making is included in monitoring
and sampling plans.

4\. Develop specific implementing procedures for ingestion pathway
protection. May include measures such as contacting food and drug
producers, inspection of outgoing shipments, quarantine or condemnation
of consumable materials, and securing of alternate food and water
supplies.

5\. Coordinate implementation of ingestion pathway protective actions.

### 2.5.8 ICS -- Based Responsibilities 

*[Incident Command]{.underline}*

1\. Based on hazard assessments, determine whether the incident poses a
risk of contamination of ingestible items (food and beverages, water,
drugs).

2\. If there is such a risk, ensure that information is developed on
water, food, beverage and drug resources within the IRZ that are
potentially at risk of contamination by chemical agent.

3\. If there is a such a risk, coordinate for performance of appropriate
sampling and analysis to assess ingestion pathway risk.

4\. Determine appropriate emergency and preventive protective actions to
protect the public against ingestion exposure to chemical agent.

5\. Provide instructions to the public regarding chosen protective
actions.

*[Planning Section]{.underline}*

1\. Gather and analyze hazard assessment information to assess the risk
of ingestion pathway exposure to chemical agent. Advise Incident
Command.

2\. Oversee performance of sampling and analysis to assess ingestion
pathway risk. Ensure that appropriate procedures are followed to protect
the integrity of samples.

3\. Develop information on water, food, beverage and drug resources
within the IRZ that are potentially at risk of contamination by chemical
agent.

*[Operations Section]{.underline}*

1\. Implement ingestion pathway protective actions as determined by
Incident Command. May include adjustment or shutoff of water utilities,
quarantine or destruction of potentially contaminated items, inspection
of shipments out of the restricted zone, securing alternate
water/food/drugs for use within the restricted zone, and other measures.

2\. Provide support as needed to sampling and analysis teams. May
include access to restricted areas, access to private property,
transport for sampling teams, and transport of samples for analysis.

*[Logistics Section]{.underline}*

1\. Secure resources to support sampling and analysis teams. May include
vehicles, supplies used in sample collection and transport,
communication equipment, and other items.

2\. Secure resources as needed to support implementation of ingestion
pathway protective actions. May include import of substitute food,
water, and drugs.

*[Finance / Administration]{.underline}*

1\. Track costs of performing ingestion pathway related sampling,
analysis, and protective actions. May include costs of substitute food,
water, and drugs.

2\. Ensure that records are maintained of decisions and actions taken on
ingestion exposure pathway protection.

## 2.6 MEDICAL SERVICES

### 2.6.1 Purpose

Recovery medical services will include preventing disease, treating
victims acutely affected by the chemical event, and assisting community
recovery via long-term physical and mental health services. *[Name of
jurisdiction]{.underline}* will ensure that the affected population
receives appropriate medical services for conditions related to the
chemical event.

### 2.6.2 Assumptions

Planning for provision of medical services during recovery from a
chemical event is based on the following assumptions:

• Medical personnel trained in the treatment of persons contaminated by
chemical agent will be available either locally, from the Army, or from
other jurisdictions through mutual aid agreements.

• Despite the best efforts of emergency management officials and staff,
emergency workers or members of the public may be exposed to harmful
levels of agent during recovery.

• The news media will demand information on health effects and any
injuries.

• Persons who were in or near the protective action area will be
concerned about the possibility of adverse health effects from the
event, and some will seek medical advice and/or an examination.

### 2.6.3 Concept of Operations

Emergency response to a chemical event will include mobilization of
medical facilities and services to provide immediate first aid and
emergency treatment to potential victims. *[Name of
jurisdiction]{.underline}* will ensure that such capabilities continue
during recovery. Exposure to harmful levels of agent is less likely
during recovery than during the early parts of the emergency and
response, but is still possible.

Medical services during recovery may include dealing with human or
animal remains. Special procedures may be required to accommodate the
technical aspect of dealing safely with potentially contaminated
remains, while allowing investigation of the deaths and final
disposition of the remains to proceed.

Medical services also will include provision of services to address the
public's concerns about the event, including medical screening and
consultation services and mental health counseling.

[Medical Services to Support Emergency Worker Operations]{.underline}

Emergency workers may be exposed to harmful levels of agent during
reentry and recovery operations due to failure of PPE or other
unforeseen circumstances. Medical facilities and staff will remain ready
to deal with such situations during recovery. In particular, operations
involving entry into restricted areas will be supported by medical
capabilities for (a) routine screening of emergency workers for agent
exposure symptoms, and (b) prompt treatment in the event that harmful
exposures occur.

Whenever one or more emergency worker teams is operating in a restricted
area, the following medical capabilities will be activated to provide
routine screening and prompt treatment capability:

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[Standby Capabilities to Evaluate and Treat Exposure
Victims]{.underline}

Members of the public may be exposed to harmful levels of agent during
recovery if they remain in or enter restricted areas that have been
evacuated. *[Name of jurisdiction]{.underline}* will ensure that medical
capabilities are available for treatment of any such cases.

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(*The capabilities required for this aspect of medical services are
similar to those needed to support emergency worker operations. However,
emergency worker operations are scheduled and coordinated in advance,
whereas a case from the public may arise at any time. Therefore, standby
capability should be available around the clock.*)

[Management of Human Remains]{.underline}

Capabilities will be activated or placed on standby, as appropriate, for
dealing with human remains. Human remains may be discovered in a
restricted area, or may originate at a medical facility when a patient
is pronounced dead.

Upon notification of a death, emergency management personnel will notify
the *[Coroner/Medical Examiner]{.underline}* and the *[Sheriff/Police
Chief]{.underline}*. Remains will not be moved or disturbed without
their approval.

If it is necessary for the *[Coroner/Medical Examiner]{.underline}* or
the *[Sheriff/Police Chief]{.underline}* to enter a restricted area to
perform an investigation, the following arrangements will be made to
support the entry.

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(*Describe arrangements for entry into the restricted area, including
issuance of PPE, monitoring and escort support, checkpoints and backup
rescue/medical teams.*)

*[Responsible public official]{.underline}* will notify the victim's
relatives once the victim's identity has been established, and will
coordinate the process of handling and releasing the remains for final
disposition in accordance with the family's preferences.

*[Responsible public official]{.underline}* will be responsible for
monitoring and decontamination of human remains. This function will be
performed in accordance with the standards and guidance in the CSEPP
Planning Guidance, Appendix M.

[Dealing with Animal Remains]{.underline}

Capabilities will be activated or placed on standby, as appropriate, for
dealing with any animal remains discovered in a restricted area.
*[Responsible public official]{.underline}* will be responsible for
removal and disposition of any such remains, including coordination as
needed with hazard analysis staff and environmental officials as needed.
Monitoring, decontamination and disposition of animal remains will be
performed in accordance with the standards and guidance in the CSEPP
Planning Guidance, Appendix M.

[Medical Services and Counseling Program]{.underline}

A program will be established to provide medical screening and follow-up
care, as well as mental health counseling for persons affected by the
emergency, including both emergency workers and members of the general
public. Medical examinations will be available for persons who would
like to be evaluated for symptoms of agent exposure. Counseling will
also be available for persons affected by the emergency.

> (*List the organizations and services to be provided.*)

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(*After a chemical event, many persons in the area, including members of
the public and emergency workers, may desire a medical evaluation for
symptoms of exposure. Some will prefer to visit a private physician, but
it may be anticipated that some will request assistance from public
authorities. Provision of initial screening and follow‑up medical care
would be both a physical and a psychological benefit to the community. A
number of organizations, including the American Red Cross and the U.S.
Army, may be willing and able to provide support in this area. It may
also be useful to contact local private physicians to provide them with
information on diagnosis and treatment of agent exposure symptoms.
Counseling and mental health services also are helpful for disaster
victims.*)

### 2.6.4 Responsibilities by Position/Organization

*[Chief Executive or Emergency Management Director]{.underline}*

1\. Assess requirements for medical services and secure resources to
fulfill them.

2\. Coordinate provision of medical services with other organizations
(*e.g., U.S. Army, American Red Cross, local hospitals, adjacent
jurisdictions*).

3\. Ensure that appropriate information is provided to the public
regarding treatment of agent exposure victims and the availability of
medical services and counseling. Ensure that information regarding any
injured persons is provided to family members prior to being
disseminated to the public.

*[Primary Implementing Organization: Health Department]{.underline}*

1\. Assess requirements for medical services during recovery and the
capability of local resources to meet them.

2\. Coordinate arrangements with emergency medical service (EMS) units
and hospitals to provide emergency treatment for emergency workers and
other possible victims.

3\. Ensure that chemical emergency-specific resources are adequate;
e.g., stocks of atropine.

4\. Coordinate arrangements for disposition of human remains, as
required, with relatives of victims, the *[coroner/medical
examiner]{.underline}*, and funeral homes.

5\. Coordinate arrangements for disposition of animal remains, as
required, with public works department, environmental authority and
waste handlers.

6\. Coordinate arrangements for a medical screening program and
follow-up care with local health care providers and other participating
organizations.

7\. Coordinate arrangements for counseling and other mental health
services.

8\. Coordinate proper disposal of any contaminated materials resulting
from provision of medical care to persons treated for chemical
event-related injuries.

9\. Determine in advance the record-keeping procedures and facilities
needed to address the health and medical needs of the community.

10\. Determine measures necessary to restore to its original and safe
condition any medical facility used in the treatment of chemical agent
exposure victims.

*[Hospitals]{.underline}*

1\. Continue treatment initiated during emergency response and care for
any new patients during recovery.

2\. Coordinate with the *[coroner/medical examiner]{.underline}*,
laboratories, PIO, and volunteer organizations to provide information to
relatives and concerned persons.

3\. Coordinate with laboratories to dispose of samples and obtain test
results.

4\. Coordinate arrangements for disposition of human remains, if
required, with relatives of victims, the *[coroner/medical
examiner]{.underline}*, and funeral homes.

*[Emergency Medical Services]{.underline}*

1\. Provide rescue or transportation services for emergency workers or
others requiring assistance, as needed.

2\. Coordinate with hospitals and other health care providers to treat
patients who may have been exposed to harmful levels of chemical agent.

*[Mental Health Organizations]{.underline}*

1\. Provide mental health services for evacuees, emergency workers, and
others who are affected by the emergency.

2\. Provide information on availability of services to the PIO at
regular intervals for as long as necessary (perhaps a year or more).

*[County Coroner/Medical Examiner]{.underline}*

1\. Coordinate information on deaths with the PIO.

2\. Coordinate with law enforcement agencies regarding investigation of
deaths, to provide security for property of deceased persons and to
notify next of kin.

3\. Supervise the disposition of human remains according to recommended
methods.

4\. Investigate circumstances of death, time, and cause.

5\. Authorize removal of human remains.

*[Law Enforcement]{.underline}*

1\. Notify Emergency Medical Services, as needed, to transport victims
to hospitals and health centers.

2\. Assist Health Department with enforcing sanitation and safety
measures.

3\. Coordinate as needed with medical personnel on investigation of any
deaths.

*[Public Information Officer]{.underline}*

1\. Obtain information from the agencies and organizations described
above about any injured persons, status of their medical treatment,
health and medical recommendations for the public, and availability of
mental health outreach services

2\. Release information to the public and news media in close
cooperation with the Public Information Office and local, state, and
federal authorities. Information pertaining to personal concerns of
victims and their families should be treated with strict
confidentiality.

*[Volunteer Organizations: American Red Cross]{.underline}*

1\. Cooperate with local, state, and federal agencies and authorities in
providing medical and mental health care to individuals located in
shelters and to others who are referred to the ARC.

(*Insert the names of the particular positions, ambulance companies or
EMSs, hospitals, and other organizations that would be involved in
medical response, and revise the responsibilities as appropriate. For
some organizations a memorandum of agreement or similar document may be
needed to ensure a secure basis for medical support during recovery.*)

### 2.6.5 ICS -- Based Responsibilities 

*[Incident Command]{.underline}*

1\. Coordinate provision of medical services with other organizations
(*e.g., U.S. Army, American Red Cross, local hospitals, adjacent
jurisdictions*).

2\. Ensure that appropriate information is provided to the public
regarding treatment of agent exposure victims and the availability of
medical services and counseling. Ensure that information regarding any
injured persons is provided to family members prior to being
disseminated to the public.

*[Planning Section]{.underline}*

1\. Assess requirements for medical services and the capability of local
resources to meet them. Advise Incident Command.

2\. Assess the need for a follow-up medical screening program for
emergency workers and/or the public. Advise Incident Command. Coordinate
arrangements for the program as needed.

3\. Assess the need for a counseling and mental health program for
emergency workers and/or the public. Advise Incident Command. Coordinate
arrangements for the program as needed.

4\. Coordinate with any medical facilities where emergency victims were
treated to determine what is necessary to restore the facility to its
original and safe condition. Advise Incident Command.

*[Operations Section (Medical Branch)]{.underline}*

1\. Provide emergency medical services for the public and emergency
workers as needed.

2\. Coordinate with local hospitals and Army medical services for
treatment of agent exposure victims and procedures for handling patients
that are potentially contaminated with agent. (*Note: only a combination
of unusual circumstances would lead to detectible contamination
off-post; see section 2.3 on hazard assessment.*)

2\. Provide for disposition of human remains, as required, in
coordination with relatives of victims, the *[coroner/medical
examiner]{.underline}*, and funeral homes.

3\. Provide for disposition of animal remains, as required, in
coordination with public works department, environmental authority and
waste handlers.

4\. Coordinate proper disposal of any contaminated materials resulting
from provision of medical care to persons treated for chemical
emergency-related injuries.

5\. Coordinate with law enforcement agencies regarding investigation of
deaths, to provide security for property of deceased persons and to
notify next of kin.

6\. Provide mental health services for evacuees, emergency workers, and
others who are affected by the emergency.

7\. Provide information on availability of services to the PIO at
regular intervals for as long as necessary (perhaps a year or more).

*[Operations Section (Coroner / Law Enforcement Branch)]{.underline}*

1\. Coordinate information on deaths with the PIO.

2\. Investigate circumstances of death, time, and cause.

3\. Authorize removal of human remains.

*[Logistics Section]{.underline}*

1\. Coordinate with nearby jurisdictions and facilities to augment
medical resources as needed. (*Emergency medical services may be needed
to "backfill" local services that are occupied with the recovery
operation.*)

2\. Ensure that chemical emergency -- specific resources are adequate;
e.g. stocks of atropine.

*[Finance/Administration]{.underline}*

1\. Track costs of performing medical services associated with the
chemical emergency.

2\. Ensure that records are maintained of medical services provided.

## 2.7 RELOCATION

### 2.7.1 Purpose 

After a chemical event involving deposition of a persistent agent, it
may be necessary to prevent unrestricted reentry of evacuated areas for
an extended period (beyond a few days). Long-term relocation of
residents, businesses, and government offices may be required. *[Name of
jurisdiction]{.underline}* will provide or seek arrangements for
services to support individuals and organizations affected by a
long-term relocation.

### 2.7.2 Concept of Operations

Long-term relocation involves a transition from a short-term evacuation
situation. Residents evacuating for a short time may initially stay with
friends or relatives, in a mass care shelter, or a motel. These options
become less attractive as the period of stay increases. For schools,
businesses and government offices, opening operations in a new location
(temporary or permanent) becomes more attractive as the relocation
period increases.

Relocation assistance can be obtained from the federal government
following a Presidential declaration of emergency or disaster.
Specifically FEMA is authorized under the Stafford Act to assist
individuals and families with relocation. Assistance may take the form
of payments to offset temporary housing costs, or direct provision of
temporary housing. The Stafford Act also authorizes the Small Business
Administration (SBA) to assist businesses with relocation and other
disaster-related costs. Annex K contains further information on
accessing these federal programs and what benefits are provided.

The following host communities have volunteered to assist with
relocation of individuals, businesses, schools, and/or other government
offices:

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(*Host communities that might shelter evacuees during emergency response
should be consulted as to whether they would also be able to provide
assistance on a longer-term basis if long-term relocation is needed.
School districts and private schools may have separate agreements with
other schools in the area to accommodate displaced students if schools
in the hazard area must remain closed for an extended period.*)

[Relocation of Individuals]{.underline}

The following activities will be carried out to support relocation of
individuals:

• Assess the need for relocation assistance if there will be a long-term
displacement.

• Identify the available internal and external resources for relocation.

• Work with FEMA to assess and develop housing options.

• Provide for community services at temporary housing locations.

• Coordinate with other jurisdictions that serve as host communities.

The following factors will be taken into account in selecting long-term
alternate housing:

• Safe housing that meets applicable building codes.

• Location is as close as possible to restricted zone.

• Family-friendly environment.

• Transportation available to schools.

• Coordinate with social service agencies to place special-needs
individuals in appropriate facilities.

[Relocation of Schools]{.underline}

The following schools are within the IRZ and may have to be relocated.
Alternate locations are provided:

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(*Inventory schools that may have to be relocated, including both public
and private schools. Where possible, identify alternate locations or
arrangements for the students that attend those schools.*)

[Relocation of other Government Agencies and Services]{.underline}

The following government offices are within the IRZ and may have to be
relocated. Alternate locations are provided:

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(*Inventory government offices that may have to be relocated due to a
chemical event. To the extent possible, identify alternate locations for
these offices.*)

[Relocation of Businesses]{.underline}

Businesses located within a restricted area may need to relocate on a
temporary basis. *[Name of jurisdiction]{.underline}* will work with the
SBA as well as local business service organizations to find suitable
locations for affected businesses and assist with setup at the new
locations, including publicizing the new location where appropriate.

### 2.7.3 Responsibilities by Position/Organization

*[Chief Executive or Emergency Management Director]{.underline}*

1\. Work with representatives of participating organizations and host
jurisdictions to develop a relocation plan.

2\. In the event that long-term relocation is needed, oversee and
coordinate relocation of individuals, businesses and government offices.
Coordinate implementation with host communities, FEMA, SBA, and service
organizations.

3\. Ensure that records are maintained of expenses associated with
relocation.

4\. Ensure that appropriate security is provided at temporary housing
areas.

*[Primary Implementing Agency: Social Services Department]{.underline}*

1\. Review mass sheltering activities already under way.

2\. Work with the following agencies to find longer-term temporary
residential placement for individuals and families displaced by the
emergency.

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3\. Coordinate with public information services to provide information
to the public on availability of relocation services.

4\. Coordinate with school officials in the affected communities to
ensure access to education for evacuated children.

5\. Arrange for transportation services, if feasible and appropriate, to
provide evacuees access to work, shopping, medical services, government
services, and places of worship.

6\. Work with the SBA, state agencies, local chambers of commerce, and
other business service groups to find long-term placement for affected
businesses.

### 2.7.4 ICS -- Based Responsibilities 

*[Incident Command]{.underline}*

1\. In the event that long-term relocation is needed, oversee and
coordinate relocation of individuals, businesses and government offices.
Coordinate implementation with host communities, FEMA, SBA, and service
organizations.

2\. Ensure the public is informed of relocation options.

*[Planning Section]{.underline}*

1\. Review mass sheltering activities already under way.

2\. Work with social service agencies and host communities to find
longer-term temporary residential placement for individuals and families
displaced by the emergency.

3\. Coordinate with school officials in the affected communities to
ensure access to education for evacuated children.

4\. Arrange for transportation services, if feasible and appropriate, to
provide evacuees access to work, shopping, medical services, government
services, and places of worship.

5\. Work with federal, state and local agencies and business-support
organizations to find longer-term temporary placement for affected
businesses and governmental offices and support resumption of business.

*[Operations Section]{.underline}*

1\. Provide relocation services to displaced residents and businesses as
required. May include transportation, setup of temporary
government-service locations, and other services.

2\. Provide security at temporary housing areas.

*[Logistics Section]{.underline}*

1\. Provide resources to support delivery of relocation services. May
include vehicles (including school buses), facilities for temporary
governmental offices, and other items.

*[Finance/Administration]{.underline}*

1\. Ensure that records are maintained of expenses associated with
relocation.

## 2.8 SOCIAL SERVICES

### 2.8.1 Purpose

Provision of social services following a chemical event is intended to
reduce the degree of human suffering and expedite return to the normal
affairs of daily life for the affected population. Social services for
those affected by the chemical event will be coordinated by *[name of
jurisdiction]{.underline}*.

### 2.8.2 Concept of Operations

It is anticipated that a chemical event will result in an increased need
for social services among the affected population. Even if actual
off-post hazard is minimal or absent, the stress of a period of
increased risk, as well as the resultant precautionary or spontaneous
protective actions, will likely cause some persons to seek social
services who otherwise would not do so. In a more severe accident
scenario, social service needs may be multiplied.

Social service needs during recovery from a chemical event will depend
on the population affected, the severity of the event, and other
factors. Some needs, such as psychological counseling, provision of food
and clothing, and employment assistance, will be similar to their
everyday counterparts. Other needs, such as assistance with relocation
and disaster aid applications, will be peculiar to a post-emergency
situation. For this reason, a wide variety of services have been planned
for; social service coordinators will determine and provide for the
particular needs of the community that are called for after a chemical
event.

### 2.8.3 Services Provided

The following services can be provided during recovery for persons
displaced, unemployed or otherwise affected by the emergency:

• Child care.

• Medical services, supplies and prescriptions.

• Mental health and social service counseling.

• Food and water.

• Clothing and personal needs.

• Transportation for those who cannot otherwise get to claims centers,
school, medical care, or shopping for basic needs.

• Assistance with applications for claims disaster aid.

• Assistance with employment or access to unemployment benefits.

• Other essential community services that may be disrupted
(e.g., banking or check-cashing services).

• Care for pets.

• Arrangements for mail service.

• Emergency communications between affected residents and family/friends
from out of town, e.g., "wellness checks."

=\>
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\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

(*Construct a list of available services including the above items
and/or others.*)

In addition, an effort will be made to deal with unplanned or impromptu
relief efforts of organizations and individuals. That effort will be
coordinated with the public information staff to publicize guidance for
those who wish to help.

### 2.8.4 Participating Agencies and Organizations

The following agencies and organizations will contribute to providing
social services during recovery:

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\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

(*This list may include state, county and municipal social service
agencies; other local jurisdictions available through mutual aid
agreements, and a variety of national, state or local volunteer and
service organizations. A partial list of national service organizations
is provided in Annex C.*)

### 2.8.5 Responsibilities by Position/Organization

*[Chief Executive or Emergency Management Director]{.underline}*

1\. Coordinate activities of participating relief and social service
organizations in *[name of jurisdiction]{.underline}*.

2\. Assess human and material resource needs.

3\. Make formal requests to other organizations for support, as needed.

4\. Coordinate with the Army and FEMA to establish disaster aid
application centers.

*[Primary Implementing Organization: Social Services
Agency]{.underline}*

1\. Development of Recovery Capabilities (Prior to Emergency)

> a\. Identify probable needs, the probable affected population, and any
> special populations that may require special services after an
> emergency.
>
> b\. Identify available resources, and establish cooperative agreements
> with other jurisdictions to cover resource shortfalls.
>
> c\. Work with the private sector to develop additional sources of
> human and material assistance as well as to encourage businesses to
> develop and/or coordinate recovery plans of their own.

2\. Initiation of Recovery Actions (Post-Emergency)

> These procedures may be initiated during the emergency response phase.
> Evaluation and reevaluation of needs and resources will be a
> continuous process.
>
> a\. Assemble support staff.
>
> b\. Identify the affected population, including any special needs
> groups, and determine the type and scale of social service needs.
>
> c\. Confirm availability of resources and identify potential resource
> shortfalls. Assist participating organizations in obtaining resources
> sufficient to fill unmet needs.
>
> d\. Provide for logistical needs such as transportation, storage and
> communications to support provision of social services.
>
> d\. Maintain regular contact with public information staff and the
> *[emergency management director/chief executive]{.underline}*.
>
> e\. Provide assistance to, and coordinate with, other agencies in
> establishing disaster application centers (or equivalent).

3\. Cost Documentation Coordination (Accounting)

> a\. Document expenses, personnel hours, and other costs of providing
> and coordinating social services.
>
> b\. Maintain records as required to comply with federal, state, and
> local regulations, as necessary, to obtain reimbursement and/or
> authorization.

### 2.8.6 ICS -- Based Responsibilities 

*[Incident Command]{.underline}*

1\. Coordinate activities of participating relief and social service
organizations.

2\. Make formal requests to other organizations for support, as needed.

3\. Coordinate opening of disaster aid application centers.

4\. Ensure the public is informed of available services.

*[Planning Section]{.underline}*

1\. Identify the affected population, including any special needs
groups, and determine the type and scale of social service needs.

2\. Confirm availability of resources and identify potential resource
shortfalls. Coordinate with other jurisdictions, volunteer
organizations, etc. to obtain resources to fill unmet needs.

*[Operations Section]{.underline}*

1\. Provide social services to persons affected by the emergency. May
include services such as counseling, housing assistance, financial
assistance, medical assistance, employment counseling, child care, and
others.

2\. Set up facilities for disaster aid centers and coordinate staffing
and equipment for them.

*[Logistics Section]{.underline}*

1\. Provide for logistical needs such as transportation, storage and
communications to support provision of social services.

2\. Arrange facilities as needed for establishment of disaster aid
centers.

*[Finance/Administration]{.underline}*

1\. Document expenses, personnel hours, and other costs of providing and
coordinating social services.

2\. Maintain records as required to comply with federal, state, and
local regulations, as necessary, to obtain reimbursement and/or
authorization.

## 2.9 PUBLIC INFORMATION

## 

### 2.9.1 Purpose

The purpose of public information and community relations during
recovery from a chemical event is to provide timely, accurate and
complete information to the public pertaining to protective actions,
health dangers, recovery efforts, available services, and other issues
of interest to the public. Each organization will contribute to public
information and ensure that its efforts are coordinated with the other
organizations.

### 2.9.2 Assumptions

After a chemical event, it may be assumed that both the public and the
media will demand information on recovery status and activities. In
particular, the public will demand information about the extent of the
chemical hazard, residual contamination, reentry, potential health
effects of exposure, compensation and assistance available, and many
other issues.

A Joint Information System (JIS) and Joint Information Center (JIC) will
have been established during the emergency response phase, including
facilities for public news media briefings and responding to public
inquiries. The JIS should continue to operate throughout the recovery
phase. The JIC may continue to function early in the recovery phase but
will not remain open indefinitely.

If there was a significant release of chemical agent, there will be a
formal remediation process under the NCP, including public hearings and
assembly of a public record of decision.

(*Providing timely, accurate and complete information to the public
about the recovery process, including public education campaigns prior
to any emergency, is an integral part of managing recovery. Public
education and information is particularly important with respect to the
process of hazard assessment that would take place after a chemical
event. Information about the hazard assessment process, including how
and why it is being conducted and how long it will take, should help
address public concerns about residual hazards and ease pressures for
return. Also it allows displaced persons to make plans based on the most
realistic possible forecast for unrestricted reentry to affected
areas.*)

### 2.9.3 Concept of Operations

The media can be an important resource during recovery in communicating
information to the public about reentry decisions, health hazards, and
recovery services offered by local, state, and volunteer agencies.

Part of the emergency response to a chemical event will be activation of
the JIS and JIC. These will continue to operate into the recovery period
as long as required to fulfill public information needs. JIC operations
during the recovery phase will be similar to those in the response
phase, although agencies represented by Public Information Officers may
change to reflect differing needs and activities in recovery verses
response. After the JIC is deactivated, information will be conveyed to
the media via normal channels (e.g., through interviews, press
conferences, press releases) and will be coordinated with other
jurisdictions via telecommunications. In addition, information will
continue to be available to the public on an individual basis through
publicized call-in telephone numbers.

The JIS will be used to coordinate public information among federal,
state and local organizations participating in recovery efforts. The
need for coordination will continue as long as there are multiple
organizations involved in the recovery.

Throughout the recovery, information will be provided through press
conferences, press releases, interviews, and public inquiries. In
addition, copies of documents associated with the recovery effort will
be made available to the public and the press. Such documents may
include monitoring and sampling plans, agreements for recovery-related
services, hazard analysis results, decision documents, and other
documents generated in the course of recovery actions.

(*Note, the news media are independent and have significant power to
influence public opinion. The news media have four major functions: to
report, to analyze and advise, to entertain, and to make a profit.
Reporters and media personnel are not necessarily allies, as they have
their jobs to perform. It is important to remember this distinction when
preparing public education and information plans for the recovery phase.
To establish a good working relationship with the media, it is
recommended to:*

• *Treat the working media with professional respect.*

• *Use an open, honest approach in briefing and informing the media.
Because the emotional effects of a disaster can persist for a
substantial time, it is a good idea to provide information to the media
on a periodic basis, particularly on the one-year anniversary of an
event.*

• *Respect the working media\'s deadlines and understand the job they
must perform. To meet this goal, for example, provide copies of plans
and other background materials that are available from other public
sources.*

• *Establish and maintain a sound working relationship with local media
personnel on a routine basis.*)

**2.9.4 Recovery Public Information Topics and Methods**

Public information efforts during the recovery phase will focus on
informing the public of protective actions, residual hazards, status of
assessment and cleanup efforts, and access to assistance and
compensation. Efforts will be made to address at least the following
topics:

• Status of any individuals suffering health effects.

• Status of hazard assessment (monitoring, sampling and evaluation) and
cleanup efforts.

• Information on residual hazards in restricted areas.

• Protocol for reentry to restricted areas.

• Relaxation of protective actions.

• Estimated time of return to restricted areas.

• Security of property in restricted areas.

• Availability of mass care and/or long-term relocation facilities.

• Availability of medical and social services for those affected by the
emergency.

• Procedures for obtaining disaster assistance and submitting claims for
compensation.

• Public concerns as expressed in inquiries received.

To maximize the effectiveness of the public information program, a
variety of methods will be used to disseminate information. In addition
to written and electronic news media, an outreach program will be
implemented to make direct contact with target populations, such as
persons at congregate care centers.

### 2.9.5 Transition from Emergency Phase Public Information Operation

The JIC will be deactivated when it is no longer needed to fulfill
public information requirements. Before deactivation takes place, media
representatives and other interested parties will be informed as to how
to obtain information after the JIC is deactivated.

Coordination among organizations and a unified voice from designated
spokespersons will continue to be important during the recovery phase
and will be maintained through JIS channels.

Throughout recovery, it is also essential that members of the public be
able to obtain information and assistance on an individual basis.
Therefore, the public inquiry telephone numbers publicized during the
emergency response phase will continue to be staffed as long as needed
during the recovery phase.

(*It is important to consider public information functions in terms of a
possibly lengthy or indefinite time frame; public information functions
may continue well after other activities have ceased. For example, there
will be media reporting on anniversaries of an event 1, 5, or 10 years
later, including interviewing current and former residents, emergency
workers, and public officials.*)

**2.9.6 Community Relations under the National Contingency Plan**

The public information function also includes developing outreach plans
and coordinating public meetings that may be required by law as part of
the environmental remediation process under the National Contingency
Plan. Public participation in the remediation decision-making process
will be promoted by:

• Ensuring that legal public participation requirements are met.

• Making public facilities available for public meetings, reading rooms,
etc.

• Publicizing opportunities for public participation.

• Representing the interests of residents on inter-jurisdictional panels
and committees.

(*If it is determined that a removal or remedial action is required
under CERCLA, Section 113 of CERCLA and Subpart I of the National
Contingency Plan (NCP) set forth the requirements for the development
and public inspection of an administrative record that contains the
documents that form the basis for selecting the response action to be
implemented. The DOD will be responsible for compiling and maintaining
the administrative record in accordance with Subpart I of the NCP.
Section 117 of CERCLA and Sections 300.415(m), 300.430(c), 300.430(f)
and Subpart I of the NCP require public participation in the development
and final selection of the removal or remedial action plan. Under
Section 300.415(m)(3) for removal actions where on-site action is
expected to extend beyond 120 days from the initiation of on-site
removal activities, the DOD will prepare a formal community relations
plan on the basis of community interviews and other relevant
information. The DOD must also prepare such a formal community relations
plan for any remedial action pursuant to Section 300.430(c)(2)(ii).*)

### 2.9.7 Responsibilities by Position/Organization

[Installation Commander]{.underline}

1\. During recovery from a chemical event, ensure that public
information released from the Installation is coordinated with off-post
jurisdictions.

2\. If a removal or remediation process is initiated under the NCP,
ensure that legal public participation requirements are met.

*[Chief Executive or Emergency Management Director]{.underline}*

1\. Prior to any emergency, ensure that public education campaigns in
the community include treatment of the recovery period.

2\. During recovery from a chemical event, ensure that public
information is coordinated among the involved organizations.

3\. Ensure that public inquiry lines are kept open until they are no
longer needed.

4\. Ensure that the public is afforded the opportunity to fully
participate in the environmental remediation process through public
hearings, public comments, and access to information regarding the
assessment and cleanup process. Make public facilities available for
this function as needed.

*[Public Information Officers (all organizations)]{.underline}*

1\. Develop material addressing the recovery period to include in public
education campaigns, including general information about the possibility
that some areas might be closed for days or weeks, and how the residual
hazard assessment process would proceed.

2\. Ensure that JIS/JIC planning includes the recovery period and any
changes in coordination procedures that occur when the JIC is
deactivated.

3\. During recovery from a chemical event, provide accurate and complete
information to the public about recovery operations, through media
briefings and interviews and through an outreach program to persons
affected by the emergency.

4\. Continue to ensure that public information is coordinated among the
involved organizations.

5\. Continue to manage the public inquiry function until it is
deactivated.

6\. Manage the process of deactivating the JIC and maintaining
coordination and continuity of public information activities after the
JIC is deactivated.

7\. Maintain a continuing public information capability after the JIC is
deactivated, including provision of information to the media for
follow-up stories on anniversaries of the event.

*[Law Enforcement Agency]{.underline}*

1\. Provide security at public information facilities. Operate a
badging/credential system for entry to the facility.

### 2.9.8 ICS -- Based Responsibilities 

*[Incident Command]{.underline}*

1\. Ensure that public information is coordinated among the involved
organizations.

2\. Ensure that public inquiry lines are kept open until they are no
longer needed.

3\. Ensure that the public is afforded the opportunity to fully
participate in the environmental remediation process through public
hearings, public comments, and access to information regarding the
assessment and cleanup process. Make public facilities available for
this function as needed.

*[Command Staff -- Public Information Officers]{.underline}*

1\. Provide accurate and complete information to the public about
recovery operations, through media briefings, interviews, and an
outreach program to persons affected by the emergency.

2\. Continue to ensure that public information is coordinated among the
involved organizations.

3\. Continue to manage the public inquiry function until it is
deactivated.

4\. Manage the process of deactivating the JIC and maintaining
coordination and continuity of public information activities after the
JIC is deactivated.

5\. Maintain a continuing public information capability after the JIC is
deactivated, including provision of information to the media for
follow-up stories on anniversaries of the event.

*[Planning Section]{.underline}*

1\. Assist public information staff as needed with planning the
transition to a post-JIC public information operation.

*[Operations Section]{.underline}*

1\. Provide security at public information facilities. Operate a
badging/credential system for entry to the facility.

2\. Advise spokespersons, as needed, on issues that may be of interest
to the public regarding implementation of recovery operations.

*[Logistics Section]{.underline}*

1\. Continue assistance in providing facilities, supplies and other
support for operation of the JIC as long as needed; then assist with
deactivation of the facility.

*[Finance/Administration]{.underline}*

1\. Track expenses associated with operation of public information
facilities.

2\. Advise spokespersons, as needed, on issues that may be of interest
to the public regarding administration and finance of the recovery
operation.

## 2.10 CLAIMS AND DISASTER ASSISTANCE

### 2.10.1 Purpose

After a chemical event, affected individuals, businesses, units of
government, and other organizations will seek disaster assistance and
compensation for damages incurred. Although claims and disaster
assistance will be primarily a function of the U.S. Army Claims Service
(USARCS), FEMA, and other federal agencies, *[name of
installation]{.underline}* and *[name of jurisdiction]{.underline}* will
use their resources to minimize delays and expedite processing and
resolution of claims and disaster assistance applications.

### 2.10.2 Concept of Operations

Timely and accurate damage assessment and prompt distribution of aid are
extremely important to community and individual recovery. This function
is best achieved by anticipating and planning for the administrative
process involved, so that the administrative structure, resources, and
procedures are quickly put in place to receive and process claims and
applications for assistance. Prompt access to assistance and
compensation will be promoted through the following measures.

(*Note, further information on claims and disaster assistance may be
found in Annexes I, J and K.*)

[Request for Disaster Declaration]{.underline}

Procedures are in place to quickly initiate a request from the Governor
to the President for a declaration of Emergency or Major Disaster under
the Stafford Act. Forms are prepared to provide the information needed
to address the criteria under which the request will be evaluated by
FEMA.

(*Under the Stafford Act, assistance to individuals and families may
include temporary housing, food, grants for expenses, crisis counseling,
legal services, disaster unemployment compensation, and other goods and
services. Governmental units may apply for assistance with public
expenses resulting from the disaster, including removal of debris and
restoration or rebuilding of public buildings and infrastructure.*)

[Assistance with Disaster Assistance Centers]{.underline}

Efforts will be coordinated among the Army, FEMA and other involved
organizations to establish Disaster Assistance Centers (DACs) at the
following locations, to provide "one-stop shopping" for persons affected
by the chemical event.

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\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

> The DACs will be staffed by:
>
> • USARCS
>
> • FEMA
>
> • Small Business Administration
>
> • *[State and local social service agencies]{.underline}*
>
> • *[Volunteer relief organizations]{.underline}*
>
> • *[Major insurance companies]{.underline}*

(*Coordinate with USARCS and FEMA regarding pre-planning for this
function. Both have plans and policies that include establishment of
disaster field offices for this purpose. A state or local jurisdiction
may be able promote a more effective DAC by helping to find or make
available suitable space, providing logistical support (e.g., office
furniture and equipment) and arranging for other organizations to join
the operation, including state and local social service agencies,
volunteer organizations such as the Red Cross, and insurance companies.
Installations may also be able to provide logistical support to this
function.*)

[Support to Individuals Filing Claims or Requests for
Assistance]{.underline}

Assistance will be provided to residents who, because of physical or
mental disabilities, language barrier, or other reasons, may have
difficulty completing the necessary paperwork.

(*Planning for this function would involve identifying staff or
volunteers who can assist individuals who need help with understanding
and/or filing the necessary forms and providing needed documentation.
Proficiency in languages other than English may be needed if there are
non-English-speaking populations within the area that might be affected.
This function should be coordinated with the Army and FEMA.*)

[Publication of Availability of Assistance]{.underline}

Public information resources will be used to make the public aware of
what assistance is available, where applications can be submitted, and
other information to facilitate public access to compensation and
disaster assistance.

### 2.10.4 Responsibilities by Position/Organization

[Installation Commander]{.underline}

1\. Work with USARCS and civilian authorities to coordinate
establishment of a disaster assistance center including facilities and
personnel for processing chemical event-related claims.

2\. Work with USARCS and civilian authorities to coordinate provision of
logistical support to the disaster assistance center. Assist civilian
authorities with planning, preparation, and recovery tasks as detailed
below under "Primary Implementing Organization."

*[Chief Executive or Emergency Management Director]{.underline}*

1\. Make formal request for disaster declaration and assistance. Oversee
submission of claims or disaster aid applications to recoup state/local
losses.

2\. Delegate responsibility for coordinating damage assessment and
disaster assistance application.

3\. Negotiate with other organizations to establish one or more
centralized disaster assistance centers.

4\. Coordinate with the Army regarding co-location of a special claims
processing center.

*[Primary Implementing Organization: Emergency Management
Agency]{.underline}*

1\. Planning and Preparatory Tasks

> a\. Assist in preparing agreements with other organizations for
> establishing one or more centralized disaster assistance centers.
>
> b\. Develop procedures for activating centralized assistance centers,
> including selection of facility, staffing, supplies, communi­cations,
> security, and other necessary arrangements.
>
> c\. Have procedures in place to quickly submit requests (and required
> documentation) to the President for declaration of an emergency or
> major disaster.
>
> d\. Develop procedures and train staff to assist individuals and
> businesses to apply for assistance.
>
> e\. Develop procedures and train staff (a Damage Assessment Team) for
> estimating damages eligible for public assistance funding.

2\. Tasks to Perform during Recovery

> a\. Gather and organize information required to support an executive
> request for disaster declaration and assistance.
>
> b\. Activate centralized assistance center(s).
>
> c\. Activate the Damage Assessment Team
>
> d\. Ensure that assistance and claims information is properly
> publicized so as to reach the affected public.
>
> e\. Provide information from government agencies that the public may
> need to document claims and requests for assistance.
>
> f\. Mobilize personnel to assist persons who need help to file a claim
> or application for assistance.

*[Public Works Director and/or Tax Assessor or Finance
Director]{.underline}*

1\. Evaluate damage or loss sustained to state/local buildings,
utilities, and other facilities, and estimate cost to repair.

2\. Track costs of responding to the chemical event.

3\. Evaluate losses due to decreased tax revenue.

4\. Submit and negotiate claims and/or disaster aid applications to
recover losses sustained by state and local government.

### 2.10.5 ICS -- Based Responsibilities 

*[Incident Command]{.underline}*

1\. Make formal request for disaster declaration and assistance.

2\. Delegate responsibility for coordinating damage assessment and
disaster assistance application.

3\. Work with USARCS, FEMA and other organizations to coordinate
establishment of a disaster assistance center including facilities and
personnel for processing chemical event-related claims and applications
for assistance.

4\. Ensure that the public is made aware of when, where and how to file
claims and/or requests for assistance.

5\. Submit and negotiate claims and/or disaster aid applications to
recover losses sustained by state and local government.

*[Planning Section]{.underline}*

1\. Gather and organize information required to support an executive
request for disaster declaration and assistance.

*[Operations Section]{.underline}*

1\. Set up and operate disaster assistance center. Provide staff to
assist members of the public who need help to file a claim or
application for assistance.

2\. Provide engineering evaluations or other support to evaluate damage
or loss sustained to state/local buildings, utilities, and other public
facilities.

*[Logistics Section]{.underline}*

1\. Assist with provision of a facility, supplies and other logistical
needs to support operation of the disaster assistance center.

*[Finance/Administration]{.underline}*

1\. Track costs of responding to the emergency.

2\. Evaluate losses sustained by governmental units, and document them
for the claims/assistance application. May include response costs,
damage to public facilities, and losses due to decreased tax revenue.

\[blank page\]

## 2.11 ENVIRONMENTAL REMEDIATION

### 2.11.1 Purpose

After a chemical event involving dispersal of chemical agent off-post,
the Army will carry out measures to assess damage and restore the
environment in the affected area, in conformance with the CAIRA manual
and applicable federal laws and regulations, and in consultation with
the U.S. EPA , state and local governments and interest groups. *[The
signatories to this plan]{.underline}* will fully cooperate in the
consultation and restoration process to ensure that public health and
safety and the environment are protected.

### 2.11.2 Assumptions

This section is based on the assumption that restoration and remediation
of off-post areas will be required. That is not necessarily the case for
all chemical event scenarios.

Army restoration and remediation actions will proceed according to AR
50-6, Department of the Army Pamphlet (DA Pam) 50-6, AR 200-1, the NCP,
and other applicable requirements and guidance. If the installation has
a chemical agent disposal facility, further requirements may apply
according to the facility permit issued under the Resource Conservation
and Recovery Act (RCRA).

### 2.11.3 Concept of Operations

Environmental response and remediation efforts will be carried out so as
to protect the health and safety of the public and the environment.

[Actions Implementing CERCLA]{.underline}

Insofar as remediation efforts are carried out pursuant to CERCLA and
the NCP, the following actions will be taken to ensure that legal
requirements are fulfilled and the interests of the public are
protected:

• The duties of the On-Scene Coordinator (OSC), as defined in CERCLA and
the NCP, will be carried out by the Installation Commander. Subsequently
those duties may be taken over by the SRF Commander.

• The U.S. EPA has considerable institutional knowledge and expertise
with respect to hazardous material spill evaluation and cleanup,
including trained OSCs and extensive contract resources for monitoring,
sampling and laboratory analysis. EPA will provide assistance with
remedial investigation, planning and scoping the cleanup process, public
hearings, and other aspects of environmental remediation, as requested
by the Army.

• The Army and civilian authorities will investigate the option of
developing an interagency agreement setting out the responsibilities of
each party for remedial action.

• Civilian authorities will participate in the planning and selection of
the remedial action, including, but not limited to, the review of all
applicable data as it becomes available and the development of studies,
reports, and action plans under (CERCLA Section 120(f)).

• Civilian authorities will identify applicable, relevant and
appropriate, and to-be-considered regulations and communicate such to
the DOD in a timely fashion.

• As natural resource trustees (*if applicable*), civilian authorities
will coordinate and cooperate with the DOD and any federal natural
resource trustees to conduct a preliminary survey of the area affected
by the release to determine if trust resources are, or potentially may
be, affected. Civilian authorities also will carry out damage
assessments and devise and carry out a plan for restora­tion,
rehabilitation, replacement, or acquisition of equivalent natural
resources.

[Actions Implementing RCRA]{.underline}

Insofar as remediation efforts are carried out pursuant to RCRA, the
following actions will be taken to ensure that legal requirements are
fulfilled and the interests of the public are protected: (*These actions
would be carried out either by the U.S. EPA or by the state
environmental protection agency, depending on whether EPA has delegated
the appropriate RCRA enforcement functions to the state. Most states
have this authority.*)

• Determine whether an administrative order should be issued under RCRA.

• Participate in negotiations for the modification of the existing
permit to provide for a remedial investigation, a corrective measures
study, and corrective action.

• Periodically review the corrective action progress and issue the
termination of the permit modification upon completion of the corrective
action.

(*Primary responsibility for the roles described above is typically at
the state level, except that applicable or relevant and appropriate
requirements (ARARS) include local requirements. At a given location,
depending on state and local law and policy, local government may also
have a consultative or even a primary role.*

*Restoration and remediation following a chemical event would be subject
to two roughly parallel sets of legal requirements, stemming from CERCLA
and RCRA and their implementing regulations. Either set could become the
primary vehicle for implementing cleanup procedures, depending on
circumstances and on the outcome of consultations between the Army, EPA,
and affected state and local governments.*

*Under CERCLA, negotiation is used to determine the requirements for
performing the remedial investigation (RI) to define the nature and
extent of the threat to the public health or welfare or the environment
caused by the release; for performing the feasibility study (FS) to
identify, evaluate, and select alternatives for the appropriate remedial
action to mitigate or abate the release; for selecting the final
remedial action and the implementation, objective, and schedule
therefore; and for identifying the ARARS of cleanup to be attained at
the site at the conclusion of the final remedial action.*

*If natural resources are or may be injured by the release, the on-scene
coordinator will ensure that state and federal trustees of the affected
natural resources are promptly notified to initiate appropriate actions,
including coordinating necessary assessments, evaluations,
investigations, and planning. States are trustees on behalf of the
public for natural resources within the boundaries of the state or
belonging to, managed by, controlled by, or applying to the state.*

*If the release is from a RCRA-permitted agent disposal facility, the
state or the EPA may issue an administrative order against DOD requiring
a corrective action under RCRA. Under RCRA, negotiation is used to
develop an amendment to the existing permit to carry out the corrective
action. A state with authorization to implement the corrective action
provisions of RCRA would negotiate the cleanup of releases from
permitted solid waste management units under RCRA Section 3004(u) or (v)
and 40 CFR Part 264. If the state is not so authorized, the U.S. EPA
would negotiate the cleanup. The U.S. EPA can also issue an
administrative order and a consent order for a cleanup under RCRA
Section 3008(h), independent of the state, for releases from the entire
"facility," which, under EPA guidance (December 16, 1985), includes the
entire site that is under the control of the owner or operator engaged
in hazardous waste management, not just from permitted solid waste
management units located at the facility. Therefore, a release from
anywhere in the entire installation may be considered by the EPA a
release from the facility under Section 3008(h).*

*Annex H contains more information on the roles and responsibilities of
the state, the Army and EPA under CERCLA and RCRA and current EPA
guidance on negotiating a cleanup agreement.*)

### 2.11.4 Responsibilities by Position/Organization

[Installation Commander]{.underline}

1\. Fulfill the duties of OSC under CERCLA and NCP unless and until
those duties are transferred to the SRF Commander.

2\. Participation in negotiations with civilian authorities to develop a
cleanup plan under CERCLA and/or RCRA.

*[Chief Executive]{.underline}*

1\. Negotiate and conclude an interagency agreement, as appropriate,
with the DOD to act as a support agency during a remedial action.

2\. Ensure that appropriate damage assessments and investigations are
carried out.

3\. Act on behalf of *[name of jurisdiction]{.underline}* in all
negotiations relating to CERCLA remedial actions and/or RCRA corrective
actions.

*[Primary Implementing Organization: Environmental Protection
Agency]{.underline}*

1\. Review and evaluate proposals for, and results from, remedial
investigations.

2\. Conduct appropriate damage assessments and investigations, including
damage to natural resources.

3\. Identify applicable, relevant and appropriate, and to-be-considered
environmental and health regulations and determine whether proposed
cleanup methods will meet them.

4\. Negotiate and/or support the chief executive in negotiating
selection of CERCLA remedial actions and/or RCRA corrective actions.

5\. Monitor progress of remedial and/or corrective actions to ensure
that restoration goals and schedules will be achieved.

### 2.11.5 ICS -- Based Responsibilities 

*[Incident Command]{.underline}*

1\. The Installation Commander will fulfill the duties of OSC under
CERCLA and the NCP unless and until those duties are transferred to the
SRF Commander.

2\. Ensure that appropriate damage assessments and investigations are
carried out.

3\. Negotiate an environmental assessment and cleanup plan, consistent
with jurisdictional responsibilities and mandated procedures under
CERCLA and RCRA, including the NCP and the disposal facility operating
permit, as appropriate.

*[Planning Section]{.underline}*

1\. Review and evaluate proposals for, and results from, remedial
investigations.

2\. Conduct appropriate damage assessments and investigations, including
damage to natural resources.

3\. Identify applicable, relevant and appropriate, and to-be-considered
environmental and health regulations and determine whether proposed
cleanup methods will meet them.

4\. Support Incident Command in developing cleanup plans.

5\. Monitor progress of remedial and/or corrective actions to ensure
that restoration goals and schedules will be achieved.

*[Operations Section]{.underline}*

1\. Support the environmental assessment process as needed.

*[Logistics Section]{.underline}*

1\. Support the environmental assessment process as needed.

*[Finance/Administration]{.underline}*

1\. Assist as needed with evaluation of damage to natural resources.

\[blank page\]

**ANNEXES**

\[blank page\]

# ANNEX A: SITE-SPECIFIC INFORMATION

Certain information required for recovery, restoration, and remediation
will be unique for each location in the Chemical Stockpile Emergency
Preparedness Program. Sources of this information should be identified
in advance. The following types of information may be useful to the
recovery effort and should be considered for inclusion in a
site-specific "data book." Most or all of this information should be
available from preexisting documents and databases. Such information may
already have been compiled as part of planning for emergency-phase
response actions.

> 1\. Environmental impact statement(s)
>
> 2\. Maps with the following information:

Political boundaries

Roads, bridges, and trails

Topography

Soil types

Geomorphology

Geology (stratigraphy and structure)

> Water resources and facilities (e.g., water treatment plants,
> irrigation facilities)

Vegetation (e.g., forestry, agriculture)

Monitoring and sampling grids

Preset monitoring points

Property boundaries

Land use, including mining and agricultural (see also item 6)

Utilities, including drainage systems

Community facilities (e.g., schools, parks, recreational areas)

> Nursing homes
>
> Prisons
>
> 3\. Meteorological data
>
> 4\. State, local, and organizational emergency plans
>
> 5\. State and local laws, regulations, and ordinances (particularly
> environmental)
>
> 6\. Databases with the following information:

Demographic

Taxes and property valuations

Commercial and economic

> Agricultural (e.g., dairies, fish hatcheries, aquaculture, apiaries,
> slaughterhouses, crops, harvest seasons, farms, markets, food
> processing and production plants, including animal feed plants,
> pharmaceutical plants)

Fish and wildlife resources

Endangered species

> 7\. Aerial photography and satellite imagery (including color and
> infrared, winter and summer)
>
> 8\. Information on local hunting seasons, game farms, and wild
> harvesting of edibles such as mushrooms.

# ANNEX B: EXTERNAL SUPPORT

Recovery from a chemical event will likely require resources beyond
those available in-house from any given jurisdiction. To meet these
needs, planners should consider, among other things:

> \(a\) Developing agreements or contingent contracts with other
> organizations to fill anticipated needs. These may be mutual aid
> agreements with neighboring jurisdictions, or agreements with private
> organizations such as charities, medical and transportation services,
> or laboratories to provide specific services in the event of an
> emergency.
>
> \(b\) Arranging ahead of time for additional procurement staff,
> perhaps borrowed from other parts of the state. Generally some
> resource needs may be anticipated, but others will come up
> unexpectedly and have to be dealt with on an ad hoc basis. To deal
> with a sudden increase in procurement requests and associated
> administrative work, including documentation of costs for later
> reimbursement, it would be prudent to have arrangements in place to
> add administrative staff on a quick and temporary basis.
>
> \(c\) Developing a streamlined procurement procedure that can be
> implemented under emergency powers following a declaration of
> emergency. In many states, under state law a declaration of emergency
> allows the chief executive to suspend legal requirements that would
> otherwise impair emergency response. To take advantage of this power,
> procedures to implement a streamlined process for procurement (or any
> other state-regulated activity) could be drawn up in advance, ready
> for sign-off after an emergency.
>
> Below is a list of the types of resources that might be needed during
> recovery from a chemical event. Of course, much will depend on local
> circumstances and needs.

[Material Resources]{.underline}

Construction equipment and supplies.

Portable housing.

Decontamination equipment and supplies.

Water purification equipment.

Boats.

Medical equipment and supplies.

Shelter and care supplies (e.g., food, clothing).

Vehicles (e.g., automobiles, vans, buses, trucks).

Agricultural equipment.

Barricades.

Protective gear and clothing.

[Human Resources]{.underline}

Recovery from a chemical event will require access to expertise in a
variety of disciplines. Advice and assistance may be obtained through
local, state, and federal agencies; public service groups; volunteer
groups; industries; and professional associations. The following list
identifies the specialties likely to be required in recovering from a
chemical accident or incident.

[Technical Experts]{.underline}:

Engineers.

Toxicologists.

Agricultural scientists.

Geologists.

Hydrologists.

Soil scientists.

Economists.

Meteorologists.

[Human Services Experts]{.underline}

Shelter managers.

Social workers.

Clergy.

Child care workers.

[Medical Experts]{.underline}

Doctors.

Nurses.

Medical technologists

Medical librarians.

Psychologists.

[Other Specialties]{.underline}

Veterinarians.

Law enforcement personnel.

Administrative personnel.

Construction workers.

Data processing specialists.

# ANNEX C: VOLUNTEER AND FAITH-BASED 

# RELIEF ORGANIZATIONS

A number of organizations can assist in providing health and social
services, including government, private, and volunteer organizations.
The following is a partial listing of such organizations. Many
additional sources of aid will exist in each community and state.

An extensive list of volunteer and faith-based disaster relief
organizations is maintained by the National Voluntary Organizations
Active in Disaster (NVOAD). A list of links may be found at NVOAD's
website, <http://www.nvoad.org/>.

It has proven helpful in some disasters to set up a coordinating council
with the authority to receive and coordinate the funds and supplies
donated by numerous organizations and individuals. Membership on the
council may include representatives of local, private, and relief
organizations.

A number of secular and faith-based relief organizations are listed
below. Every faith has numerous charitable and relief organizations.
This list represents a sampling, drawn primarily from the links on the
NVOAD website. Presence on this list is does not represent an
endorsement or recommendation by the CSEP program. Rather, the list is
provided for information and assistance to state and local emergency
planners in developing resources for disaster recovery.

**SECULAR RELIEF SERVICE ORGANIZATIONS**

[American Red Cross (ARC)]{.underline}

The ARC was chartered by Congress in 1905 to provide assistance in
disasters. They have provided shelter and housing assistance, food,
grants and general assistance, and counseling services. Warehouses,
located in various parts of the United States, store emergency items,
food, and blankets. An important service provided by the ARC is
supervision of shelter operations. In addition, the ARC cooperates with
and coordinates activities of other relief organizations.

National Headquarters

18th and E Streets, N.W.

Washington, DC 20006

Website: <http://www.redcross.org/>

[National Voluntary Organizations Active in Disaster
(NVOAD)]{.underline}

NVOAD coordinates planning efforts by many voluntary organizations
responding to disaster. Member organizations provide more effective and
less duplication in service by getting together before disasters strike.
Once disasters occur, NVOAD or an affiliated state VOAD encourages
members and other voluntary agencies to convene on site.

John Gavin, Executive Secretary

14253 Ballinger Terrace

Burtonsville, MD 20866

Phone: 301‑890‑2119

Fax: 253‑541‑4915

Email: jgavin2@starpower.net

Website: <http://www.nvoad.org/>

[American Psychological Association Disaster Response
Network]{.underline}

Over 1,500 psychologist volunteers provide free, onsite mental health
services to disaster survivors and the relief workers who assist them.
The APA coordinates this service with the Red Cross, FEMA, and state and
local emergency management agencies.

American Psychological Association

750 First Street, NE

Washington, DC 20002‑4242.

Telephone: 800‑374‑2721; 202‑336‑5510. TDD/TTY: 202‑336‑6123

Website: <http://www.apa.org/practice/drnindex.html>

**FAITH-BASED RELIEF ORGANIZATIONS**

[American Friends Service Committee]{.underline}

> 1501 Cherry Street

Philadelphia, PA 19102

Phone: (215) 241‑7000

Fax: (215) 241‑7275

E‑mail: afscinfo@afsc.org

website: [http://www.afsc.org](http://www.afsc.org/)

[Catholic Charities USA]{.underline}

Catholic Charities USA

1731 King Street #200

Alexandria, Virginia 22314

Phone: (703) 549‑1390

Fax: (703) 549‑1656

website: <http://www.catholiccharitiesusa.org/disaster/index.htm>

[Christian Disaster Response International]{.underline}

PO Box 3339

Winter Haven, FL 33885‑3339

Voice: 863.551.9554

Fax: 863.551.8166

Email: drpat@gte.net

Website: <http://www.cdresponse.org/cdrhome.html>

[Church World Service]{.underline}

Church World Service Emergency Response Program

475 Riverside Drive (#606)

New York, NY 10115

Telephone: (212) 870‑3151

Fax: (212) 870‑2236

24‑Hour Pager: (800)‑780‑0853

E‑Mail: Rick Augsburger, Director: raugs@aol.com

Website: <http://www.cwserp.org/>

[Evangelical Lutheran Church in America]{.underline}

ELCA Domestic Disaster Response

8765 West Higgins Road

Chicago, IL 60631

Telephone: 800.638‑3522, ext. 2822 (direct: 773.380.2822)

Fax: 773.380.2707

Website: <http://wwwtest.elca.org/disaster/>

[Mennonite Disaster Service]{.underline}

1018 Main St

Akron, PA 17501

Phone: 717‑859‑2210

Fax: 717‑859‑4910

E‑Mail: mds@mdsbinat.org

website: <http://www.mds.mennonite.net/>

[Presbyterian Disaster Assistance]{.underline}

100 Witherspoon Street

Louisville, KY 40202‑1396

Phone: 1‑800‑872‑3283

Website: <http://www.pcusa.org/pda/index.html>

[Salvation Army]{.underline}

National Headquarters

120 West 14th Street

New York, NY 10011

Phone: (888) 234 8888 or (212) 337 7200

Fax: (212) 337 7478

website: <http://www.salvationarmy.org/>

[Southern Baptist Disaster Relief]{.underline}

North American Mission Board, SBC

4200 North Point Parkway

Alpharetta, Georgia 30022‑4176

Phone: (770) 410‑6000

Fax: (678) 410‑6018

Website: <http://www.namb.net/dr/pages/beginnings.asp>

[United Jewish Communities]{.underline}

United Jewish Communities

Suite 11E

111 Eighth Ave.

New York, NY 10011

Phone: 212.284.6500

Website: [http://www.ujcna.org](http://www.ujcna.org/)

[United Methodist Church Committee on Relief]{.underline}

475 Riverside Drive

> Room 1470

New York, NY 10115

Phone: 1‑800‑554-8583

Website: <http://gbgm-umc.org/umcor/emergency.stm>

[Volunteers of America]{.underline}

Volunteers of America

National Office

660 Duke Street

Alexandria, VA 22314‑3421

Toll Free: (800) 899‑0089

Phone: (703) 341‑5000

Fax: (703) 341‑7000

Email: voa@voa.org

Website: <http://www.voa.org/>

\[blank page\]

# ANNEX D: TECHNICAL CONTACTS

Telephone numbers and websites for selected federal government and
national private organizations are listed below.

+-----------------------+----------------------------------------------+
| Organization          | Contact Information                          |
+=======================+==============================================+
| Agency for Toxic      | Information 888‑422‑8737 or 404‑498‑0110     |
| Substances and        |                                              |
| Disease Registry      | Emergency: (404) 498‑0120                    |
| (ATSDR)               |                                              |
|                       | <http://www.atsdr.cdc.gov/>                  |
+-----------------------+----------------------------------------------+
| Centers for Disease   | Phone: 404 639‑3311                          |
| Control (CDC)         |                                              |
|                       | [http://www.cdc.gov](http://www.cdc.gov/)    |
| -- National Center    |                                              |
| for Environmental     | Phone: 770‑488‑7100                          |
| Health                |                                              |
|                       | <http://www.cdc.gov/nceh/>                   |
| -- National Institute |                                              |
| for Occupational      | Phone: 800‑356‑4674                          |
| Safety and Health     |                                              |
|                       | <http://www.cdc.gov/niosh/homepage.html>     |
+-----------------------+----------------------------------------------+
| Environmental         | RCRA/Superfund/EPCRA information center:     |
| Protection Agency     |                                              |
| (EPA)                 | 800 424‑9346 or 703 412‑9810                 |
|                       |                                              |
| -- Chemical Emergency | [http://www.epa.gov](http://www.epa.gov/)    |
| Preparedness and      |                                              |
| Prevention Office     | <http://www.epa.gov/ceppo/>                  |
+-----------------------+----------------------------------------------+
| National Institute    | \(304\) 346‑6264                             |
| for Chemical Studies  |                                              |
|                       | <http://www.nicsinfo.org/>                   |
+-----------------------+----------------------------------------------+
| National Fire         | 617 770‑3000                                 |
| Protection            |                                              |
| Association           | [http://www.nfpa.org](http://www.nfpa.org/)  |
+-----------------------+----------------------------------------------+
| National Response     | emergency hotline: 800 424 8802              |
| Center (spill         |                                              |
| reporting)            | <http://www.nrc.uscg.mil/index.htm>          |
+-----------------------+----------------------------------------------+
| Occupational Safety   | 800‑321‑OSHA (6742)                          |
| and Health            |                                              |
| Administration        | <http://www.osha-slc.gov/index.html>         |
+-----------------------+----------------------------------------------+

\[blank page\]

# ANNEX E: PERSONAL PROTECTIVE EQUIPMENT

The following garments and equipment are approved for CSEPP use. Source:
communication from Robert Weiss, SBCCOM, 7 February 2002.

**Commercial Protective Suits**

[Manufacturer/Supplier]{.underline} [Model/Style]{.underline}
[Number]{.underline}

Kappler Responder Coverall 41255

Kappler CPF3 Coverall 3T428

ADI Technologies Mark IV Overgarment [NATO Stock No.]{.underline}

Olive Drab 8415-99-130-7748/7751

Woodland 8415-99-130-6921/24&6940

Desert 8415-99-130-7086/7090

**Commercial Powered Air Purifying Respirators**

[PAPR]{.underline} [Cartridge]{.underline} [NIOSH Approval
No.]{.underline}

KASCO Venus T8 ZAP3 TC-23C-1811

MSA Optimair 6A GMA-H TC-23C-1263

MSA Optimair 6A GMC-H TC-23C-1056

Neoterik TF3 NP2532 TC-23C-1529

3M BE7 AP3 TC-23C-0483

3M BE7 AEP3 TC-23C-0647

3M BE7 FR-57 TC-23C-2072

3M BE10 AP3 TC-23C-1885

3M BE10 AEP3 TC-23C-1884

3M BE10 FR-57 TC-23C-2071

3M GVP-4M GVP-443 TC-23C-1478

**DOD Protective Equipment**

[Item]{.underline} [NSN]{.underline} [Size]{.underline}

Chemical Protective Glove (25 mil) 8415-01-033-3517 S

Chemical Protective Glove (25 mil) 8415-01-033-3518 M

Chemical Protective Glove (25 mil) 8415-01-033-3519 L

Chemical Protective Glove (25 mil) 8415-01-033-3520 XL

Chemical Protective Glove (14 mil) 8415-01-138-2497 S

Chemical Protective Glove (14 mil) 8415-01-138-2498 M

Chemical Protective Glove (14 mil) 8415-01-138-2499 L

Chemical Protective Glove (14 mil) 8415-01-138-2500 XL

**DOD Protective Equipment cont'd**

[Item]{.underline} [NSN]{.underline} [Size]{.underline}

Chemical Protective Glove (7 mil) 8415-01-138-2501 S

Chemical Protective Glove (7 mil) 8415-01-138-2502 M

Chemical Protective Glove (7 mil) 8415-01-138-2503 L

Chemical Protective Glove (7 mil) 8415-01-138-2504 XL

Cotton Glove Insert 8415-01-138-2494 S

Cotton Glove Insert 8415-01-138-2495 M

Cotton Glove Insert 8415-01-138-2496 L

Black Vinyl Overboots (BVO) 8430-01-317-3374 3

Black Vinyl Overboots (BVO) 8430-01-317-3375 4

Black Vinyl Overboots (BVO) 8430-01-317-3376 5

Black Vinyl Overboots (BVO) 8430-01-317-3377 6

Black Vinyl Overboots (BVO) 8430-01-317-3378 7

Black Vinyl Overboots (BVO) 8430-01-317-3379 8

Black Vinyl Overboots (BVO) 8430-01-317-3380 9

Black Vinyl Overboots (BVO) 8430-01-317-3381 10

Black Vinyl Overboots (BVO) 8430-01-317-3382 11

Black Vinyl Overboots (BVO) 8430-01-317-3383 12

Black Vinyl Overboots (BVO) 8430-01-317-3384 13

Black Vinyl Overboots (BVO) 8430-01-317-3385 14

Black Vinyl Overboots (BVO) 8430-01-450-0359 15

Black Vinyl Overboots (BVO) 8430-01-450-0357 16

Black Vinyl Overboots (BVO) 8430-01-450-0358 17

Black Vinyl Overboots (BVO) 8430-01-450-0360 18

Toxicological Agent Protective Apron 8415-00-281-7813 S

Toxicological Agent Protective Apron 8415-00-281-7814 M

Toxicological Agent Protective Apron 8415-00-281-7815 L

Toxicological Agent Protective Apron 8415-00-281-7816 XL

Chemical Protective PAPR Hood N/A N/A

Kit, Bag Flyers (Ready Bag) 8460-00-606-8366 N/A

# ANNEX F: CHEMICAL AGENT EXPOSURE STANDARDS

The chemical agent exposure standards in the tables below have been
published by military and civilian authorities, in either proposed or
final form. There are standards for air, drinking water, soil, and total
chronic exposure. The standards are based on prevention of long-term
toxic effects. In general the standards were not developed specifically
as a basis for CSEPP recovery decisions. Some were developed as a basis
for determining the need for use of personal protective equipment. The
soil contamination standards were evaluated primarily for purposes of
determining whether contaminated areas on-post can be leased or conveyed
for civilian redevelopment.

In addition to these standards, standards for milk and unprocessed
produce have been proposed in a Technical Memorandum by Oak Ridge
National Laboratory (see Watson et al., *Estimated General Population
Control Limits for Unitary Agents in Drinking Water, Milk, Soil, and
Unprocessed Food Items*, ORNL/TM-12035, Oak Ridge, Tenn. (Jan. 1992).

<table>
<colgroup>
<col style="width: 8%" />
<col style="width: 9%" />
<col style="width: 10%" />
<col style="width: 9%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 20%" />
</colgroup>
<thead>
<tr class="header">
<th colspan="11"><p><strong>Table F-1: Chemical Agent Multi
Media/Toxicity Standards Status Table: Existing and proposed
criteria</strong></p>
<p><strong>as of <mark><u>3/19/01</u></mark> POC: V. Hauschild,
USACHPPM</strong></p></th>
</tr>
<tr class="odd">
<th><strong>Media</strong></th>
<th><strong>Standard</strong></th>
<th><strong>Population</strong></th>
<th><p><strong>Exposure</strong></p>
<p><strong>Scenario</strong></p></th>
<th><strong>H/HD/HT (Mustard)</strong></th>
<th><p><strong>GA</strong></p>
<p><strong>(Tabun)</strong></p></th>
<th><p><strong>GB</strong></p>
<p><strong>(Sarin)</strong></p></th>
<th><strong>GD/GF</strong></th>
<th><strong>VX</strong></th>
<th><strong>Lewisite</strong></th>
<th><blockquote>
<p><strong>Notes</strong></p>
<p>(also see notes after table)</p>
</blockquote></th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td rowspan="3"><h1 id="water">WATER</h1></td>
<td rowspan="3"><p><strong>FDWS</strong></p>
<p>(Field Drinking Water Standards) ug/L</p></td>
<td rowspan="3">soldier</td>
<td>Safe for up to 7 days:</td>
<td><em><del>200</del><sup>a</sup></em></td>
<td><em><del>20</del> <sup>a</sup></em></td>
<td><em><del>20</del> <sup>a</sup></em></td>
<td><em><del>20</del> <sup>a</sup></em></td>
<td><em><del>20</del> <sup>a</sup></em></td>
<td><em><del>200</del> <sup>a</sup></em></td>
<td rowspan="3"><p>1986 version is being superceded; new values shown
have been endorsed by DOD (see memo ref.).</p>
<p>Currently revised TBMed577 is a DRAFT dated May 99; final publication
date TBD.</p>
<p>Nerve agent standards based on most toxic since field detection can’t
differentiate – specific standards include tabun – 140/46; sarin –
28/9/3; soman – 12/4; VX – 15/5.</p></td>
</tr>
<tr class="even">
<td>Normal/humid climate: 5 L/day</td>
<td><strong>(140)</strong> <em><sup>b</sup></em></td>
<td><strong>(12*</strong> <em><sup>b</sup></em><strong>)</strong></td>
<td><strong>(12*</strong> <em><sup>b</sup></em><strong>)</strong></td>
<td><strong>(12*</strong> <em><sup>b</sup></em><strong>)</strong></td>
<td><strong>(12*</strong> <em><sup>b</sup></em><strong>)</strong></td>
<td><strong>(80</strong> <em><sup>b</sup></em><strong>)</strong></td>
</tr>
<tr class="odd">
<td><p>Dry climate:</p>
<p>15 L/day</p></td>
<td><strong>(47</strong> <em><sup>b</sup></em><strong>)</strong></td>
<td><strong>(4*</strong> <em><sup>b</sup></em><strong>)</strong></td>
<td><strong>(4*</strong> <em><sup>b</sup></em><strong>)</strong></td>
<td><strong>(4*</strong> <em><sup>b</sup></em><strong>)</strong></td>
<td><strong>(4*</strong> <em><sup>b</sup></em><strong>)</strong></td>
<td><strong>(27</strong> <em><sup>b</sup></em><strong>)</strong></td>
</tr>
<tr class="even">
<td rowspan="2"><h1 id="section-1"></h1>
<p><strong>SOIL</strong></p>
<p>(mg/kg)</p>
<p>(ppm)</p></td>
<td><p><strong>HBESL-Residential</strong></p>
<p>(Health-Based</p>
<p>Environmental</p>
<p>Screening Level)</p></td>
<td>adults and children</td>
<td><p>Daily exposure,</p>
<p>lifetime</p></td>
<td><strong>0.01</strong> <em><sup>c,d</sup></em></td>
<td><strong>2.8</strong> <em><sup>c,d</sup></em></td>
<td><strong>1.3</strong> <em><sup>c,d</sup></em></td>
<td><strong>0.22</strong> <em><sup>c,d</sup></em></td>
<td><strong>0.042</strong> <em><sup>c,d</sup></em></td>
<td><strong>0.3</strong> <em><sup>c,d</sup></em></td>
<td rowspan="2"><p>- EPA Region IX PRG soil risk</p>
<p>assessment methods used;</p>
<p>- Uses GPLs and chronic toxicity values cited below</p>
<p>( RfD, CSF, IUR)</p>
<p>- Endorsed by DA (ESOH); May 99</p></td>
</tr>
<tr class="odd">
<td><strong>HBESL-Industrial</strong></td>
<td>adults</td>
<td><p>Frequent</p>
<p>exposures 250 days/yr. for 30 years</p></td>
<td><strong>0.3</strong> <em><sup>c,d</sup></em></td>
<td><strong>68</strong> <em><sup>c,d</sup></em></td>
<td><strong>32</strong> <em><sup>c,d</sup></em></td>
<td><strong>5.2</strong> <em><sup>c,d</sup></em></td>
<td><strong>1.1</strong> <em><sup>c,d</sup></em></td>
<td><strong>3.7</strong> <em><sup>c,d</sup></em></td>
</tr>
</tbody>
</table>

<table style="width:100%;">
<colgroup>
<col style="width: 8%" />
<col style="width: 9%" />
<col style="width: 11%" />
<col style="width: 9%" />
<col style="width: 8%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 17%" />
</colgroup>
<thead>
<tr class="header">
<th colspan="11"><p><strong>Table F-1: Chemical Agent Multi
Media/Toxicity Standards Status Table: Existing and proposed
criteria</strong></p>
<p><strong>as of <mark><u>3/19/01</u></mark> POC: V. Hauschild,
USACHPPM</strong></p></th>
</tr>
<tr class="odd">
<th><strong>Media</strong></th>
<th><strong>Standard</strong></th>
<th><strong>Population</strong></th>
<th><p><strong>Exposure</strong></p>
<p><strong>Scenario</strong></p></th>
<th><strong>H/HD/HT (Mustard)</strong></th>
<th><p><strong>GA</strong></p>
<p><strong>(Tabun)</strong></p></th>
<th><p><strong>GB</strong></p>
<p><strong>(Sarin)</strong></p></th>
<th><strong>GD/GF</strong></th>
<th><strong>VX</strong></th>
<th><strong>Lewisite</strong></th>
<th><blockquote>
<p><strong>Notes</strong></p>
<p>(also see notes after table)</p>
</blockquote></th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td rowspan="3"><h1 id="section-2"></h1>
<p><strong>WASTE</strong></p></td>
<td><p><strong>HWCL<sub>sol</sub><sup>e</sup></strong> <em>or</em>
<strong>LDR<sub>sol</sub><sup>f</sup></strong> (solid</p>
<p>hazardous waste)</p>
<p>(mg/kg)</p></td>
<td><p>civilian/ DoD</p>
<p>worker</p></td>
<td><p>Possible</p>
<p>occasional exposure</p>
<p>at HW treatment</p>
<p>facility</p></td>
<td><strong>6.7</strong> <sup>e,f</sup></td>
<td><strong>680</strong> <sup>e,f</sup></td>
<td><strong>320</strong> <sup>e,f</sup></td>
<td><strong>52</strong> <sup>e,f</sup></td>
<td><strong>10</strong> <sup>e,f</sup></td>
<td><strong>37</strong> <sup>e,f</sup></td>
<td rowspan="3"><p>- EPA Reg IX PRG risk assessment methods used.</p>
<p>- Uses GPLs and chronic toxicity values ( RfD, CSF, IUR).</p>
<p>- Proposed in a Department of Army proposed rule presented to the
State of Utah and Oct 2000 CHPPM memo to PMCD; to date no official Utah
State response received.</p>
<p>-Waste values not represented in any final report policy or guidance
document.</p></td>
</tr>
<tr class="even">
<td><p><strong>HWCL<sub>Liq</sub><sup>e</sup></strong> <em>or</em>
<strong>LDR<sub>Liq</sub><sup>f</sup></strong> (liquid</p>
<p>hazardous waste)</p>
<p>(mg/L)</p></td>
<td>civilian/ DoD worker</td>
<td><p>Possible</p>
<p>occasional exposure</p>
<p>at HW treatment</p>
<p>facility</p></td>
<td><strong>0.7</strong> <sup>e,f</sup></td>
<td><strong>20</strong> <sup>e,f</sup></td>
<td><strong>8.3</strong> <sup>e,f</sup></td>
<td><strong>0.3</strong> <sup>e,f</sup></td>
<td><strong>0.08</strong> <sup>e,f</sup></td>
<td><strong>3.3</strong> <sup>e,f</sup></td>
</tr>
<tr class="odd">
<td><p><strong>NHWCL<sup>e</sup></strong> <em>or</em> <strong>Solid
Waste</strong></p>
<p><strong>Exemption</strong></p>
<p><strong>Levels<sup>f</sup></strong></p>
<p>(mg/kg or ppm)</p></td>
<td>civilian/ DoD worker</td>
<td><p>At a non-HW</p>
<p>land disposal facility,</p>
<p>possible occasional</p>
<p>exposures</p></td>
<td><strong>0.3</strong> <sup>e,f</sup></td>
<td><strong>68</strong> <sup>e,f</sup></td>
<td><strong>32</strong> <sup>e,f</sup></td>
<td><strong>5.2</strong> <sup>e,f</sup></td>
<td><strong>1.1</strong> <sup>e,f</sup></td>
<td><strong>3.7</strong> <sup>e,f</sup></td>
</tr>
<tr class="even">
<td rowspan="3"><p><strong>Chronic</strong></p>
<p><strong>Toxicity</strong></p>
<p><strong>Criteria</strong></p></td>
<td><p><strong>RfD</strong> (Reference</p>
<p>Dose)</p>
<p>(mg/kg/day)</p></td>
<td>civilian population</td>
<td><p>Chronic (lifetime)</p>
<p>ingested dose that will produce adverse health</p>
<p>effects</p></td>
<td><strong>0.000007</strong> <sup>g,h,I, j</sup></td>
<td><strong>0.00004</strong> <sup>g,h,I, j</sup></td>
<td><strong>0.00002</strong> <sup>g,h,I, j</sup></td>
<td><strong>0.000004</strong> <sup>g,h,I, j</sup></td>
<td><strong>0.0000006</strong> <sup>g,h,I, j</sup></td>
<td><strong>0.0001</strong> <sup>g,h,I, j</sup></td>
<td>NRC/COT (1999) gave general endorsement of values ; outstanding
issues (e.g. re: Lewisite ) were addressed in Final DA OTSG endorsement
letter of final RfDs (dated 16 Feb 2000)</td>
</tr>
<tr class="odd">
<td><p><strong>CSF</strong> (Cancer Slope Factor)</p>
<p>(mg/kg/day)</p></td>
<td>civilian population</td>
<td>Potency of the agent by ingestion to increase cancer risk.</td>
<td><strong>7.7</strong> <sup>g,c</sup></td>
<td colspan="5" rowspan="2">Not determined to be a carcinogen.</td>
<td>- The NRC/1999 endorsed a less conservative HD Slope Factor of (1.6
mg/kg/day)<sup>-1</sup>; DA OTSG (Feb 00) has currently endorsed use of
the 7.7</td>
</tr>
<tr class="even">
<td><p><strong>IUR</strong></p>
<p>Inhalation Unit Risk ) (ug/m<sup>3</sup>)<sup>-1</sup></p></td>
<td>civilian population</td>
<td>Potency of the agent by inhalation to increase cancer risk</td>
<td><strong>4.1 x 10<sup>-3 k</sup></strong></td>
<td>Table 20 HD HCD, Nov. 2000</td>
</tr>
</tbody>
</table>

**[Notes and References for Table F-1]{.underline}**

( ) numbers in parentheses are from draft sources

**GREEN** Numbers in Green are currently documented in official Army
regulation/policy/or through DA Headquarter endorsement.

**BLUE** Numbers have been developed/endorsed by non-DoD federal
proponents for Army and non-Army use.

**RED** Numbers are still officially used/endorsed by Army/other
approving entity source but revisions are proposed/underway.

**BLACK** Numbers black are final technical values but are not
officially approved for implementation through a proponent agency.

**[REFERENCES]{.underline}**:

a\) TB Med 577, *Sanitary Control and Surveillance of Field Water
Supplies*, March 1986.

b\) TB Med 577, *Sanitary Control and Surveillance of Field Water
Supplies*, final DRAFT May 1999 (final/official publication date TBD)
and Memorandum, DASG-HS-PE, 16 April 1997, Subject:  Tri-Service Field
Water Standards for Nerve Agents.

c\) *Health-Based Environmental Screening Levels for Chemical Warfare
Agents*, USACHPPM/ORNL Technical Report, March 99.

d\) Memorandum, Headquarters Department of the Army, Office of the
Assistant Secretary for Installations, Logistics, and Environment, SUBJ:
Derivation of Health-Based Environmental Screening Levels (HBESLs) for
Chemical Warfare Agents, May 28 1999.

e\) Memorandum, Department of the Army -- Center for Health Promotion
and Preventive Medicine; MCHB-TS-EES; SUBJ: Response to State of Oregon
Comments on the Utah Chemical Agent Rule (UCAR), 23 October 2000. NOTE:
This response includes USACHPPM Information Paper, *Management Criteria
for Chemical Warfare Agent (CWA)-Contaminated Waste and Media,* dated 10
October 2000, as well as USACHPPM Technical Paper, *Chemical Warfare
Agent Health-Based Waste Control Limits,* dated September 2000.

f\) U.S. Army --Proposed Utah Chemical Agent Rule (UCAR), May 1999
(Volume 1, Section XI. Development of Health-Based Waste Management
Concentration Levels).

g\) Memorandum, MCHB-CG-PPM, Chronic Toxicological Criteria for Chemical
Warfare Compounds, 16 February 2000.

h\) Review of the U.S. Army's Health Risk Assessments for Oral Exposure
to Six Chemical-Warfare Agents, *National Research Council, National
Academy Press, Washington, D.C., 1999.*

i\) Opresko et. al, *Chemical Warfare Agents: Estimating Oral Reference
Doses, Review of Environmental Contamination and Toxicology*, Vol 156,
pp 1-183, 1998.

j\) DA 1996, *Interim Chronic Toxicological Criteria for Chemical
Warfare Compounds*, Memorandum MCHB-DC-C, 4 June 1996, Office of the
Surgeon General.

k\) CHPPM Technical Report: *Evaluation of Airborne Exposure Limits for
Sulfur Mustard (HD): Occupational and General Population Exposure
Criteria,* Technical Report 47-EM-3767-00**,** November, 2000.

**[ADDITIONAL INFORMATION REGARDING CWA BREAKDOWN
PRODUCTS:]{.underline}**

Munro et al.; *The Sources, Fate, and Toxicity of Chemical Warfare Agent
Degradation Products,* Environmental Health Perspectives, Volume 107,
Number 12, December 1999 pp933-974.

<table style="width:100%;">
<colgroup>
<col style="width: 15%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 0%" />
<col style="width: 7%" />
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 19%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="11"><strong>Table F-2: Chemical Agent Air Standards Status,
existing and proposed standards as of 9/11/02. POC: V. Hauschild,
USACHPPM</strong></td>
</tr>
<tr class="even">
<td colspan="11"><strong>Airborne Exposure Limits (AELs)
(mg/m<sup>3</sup>)</strong></td>
</tr>
<tr class="odd">
<td><strong>Standard</strong></td>
<td><p><strong>Popula-</strong></p>
<p><strong>tion</strong></p></td>
<td colspan="2"><strong>Exposure Scenario</strong></td>
<td><strong>H/HD/HT</strong></td>
<td><strong>GA (Tabun)</strong></td>
<td><strong>GB (Sarin)</strong></td>
<td><strong>GD/GF</strong></td>
<td><strong>VX</strong></td>
<td><strong> Lewisite</strong></td>
<td><strong>Notes/ Status</strong></td>
</tr>
<tr class="even">
<td rowspan="2"><p><strong>IDLH</strong></p>
<p>(Immediately Dangerous to Life/Health)</p></td>
<td rowspan="2"><p>Civilian/</p>
<p>DoD worker</p></td>
<td rowspan="2">1 time exposure</td>
<td colspan="2">NA</td>
<td><strong><em> 0.2</em> <sup>a, b </sup></strong></td>
<td><strong><em> 0.2</em> <sup>a, b</sup></strong></td>
<td><strong><em> 0.06</em><sup>a,b</sup></strong></td>
<td><strong><em> 0.02</em> <sup>a,b</sup></strong></td>
<td>NA</td>
<td rowspan="10"><p>-- IDLH, WPL, STEL, and GPL values from final Army
technical re-evaluation reports.</p>
<p>-- Revisions to existing criteria NOT officially established in Army
policy as of 5/01 but Internal (MEDCOM) staffing of revised Army
regulation (DA Pam 40-8, 40-173) underway; Goal is to finalize DA Pams
by end FY02.</p>
<p>-- STEL is new <strong>proposed</strong> standard not previously
established.</p>
<p>NOTE: CDC has proposed modified (lower than new Army proposed) values
for the nerve agents in the <em>Federal Register</em> (Jan 8 2002; 67
FR: 894-901) The Army non-concurred with the CDC modifications (see
reference h). No final CDC position has been identified. CDC is
currently evaluating the Army proposed HD values. (references c, d
e).</p>
<p>-- No re-evaluation of Lewisite has been performed. NOTE: Lewisite
values are all based on detection; no true IDLH exists (AR 385-61, Table
2-2,</p>
<p>2-3)</p></td>
</tr>
<tr class="odd">
<td colspan="2"><strong>2<sup>c</sup></strong></td>
<td><strong>0.1 <sup>d</sup></strong></td>
<td><strong>0.1 <sup>d</sup></strong></td>
<td><strong>0.05 <sup>d</sup></strong></td>
<td><strong>0.01 <sup>e</sup></strong></td>
<td>NA</td>
</tr>
<tr class="even">
<td rowspan="2"><p><strong>STEL</strong></p>
<p>(Short Term Exposure Limit)</p></td>
<td rowspan="2"><p>Civilian/DoD worker</p>
<p> </p></td>
<td rowspan="2">occasional 15-minute exposure (4x ea day)</td>
<td colspan="2"><strong>0.003<sup>c</sup></strong></td>
<td><strong>0.0004 <sup>d</sup></strong></td>
<td><strong>0.0004 <sup>d</sup></strong></td>
<td><strong>0.0002<sup>d</sup></strong></td>
<td><strong>0.00004<sup>e</sup></strong></td>
<td>NA</td>
</tr>
<tr class="odd">
<td colspan="2"><em><strong>(see note)</strong></em></td>
<td><em><strong>(see note)</strong></em></td>
<td><em><strong>(see note)</strong></em></td>
<td><em><strong>(see note)</strong></em></td>
<td><em><strong>(see note)</strong></em></td>
<td>NA</td>
</tr>
<tr class="even">
<td rowspan="3"><p><strong>WPL</strong></p>
<p>(Worker Population Limit) </p></td>
<td rowspan="3"><p>Civilian/</p>
<p>DoD worker</p>
<p> </p>
<p> </p></td>
<td rowspan="3"><p>8-hr daily/</p>
<p>30-yr. time-</p>
<p>weighted average</p></td>
<td colspan="2"><strong> <em> 0.003</em> <sup>b,f,g</sup></strong></td>
<td><strong><em> 0.0001</em> <sup>a,b,g</sup></strong></td>
<td><strong><em> 0.0001</em> <sup>a,b,g</sup></strong></td>
<td><strong><em> 0.00003</em> <sup>a,b,g</sup></strong></td>
<td><strong><em> 0.00001</em><sup>a,b,g</sup></strong></td>
<td><strong><em>0.003</em> <sup>a,b</sup></strong></td>
</tr>
<tr class="odd">
<td colspan="2"><strong>0.0004<sup>c</sup></strong></td>
<td><strong>0.0001 <sup>d</sup></strong></td>
<td><strong>0.0001<sup>d</sup></strong></td>
<td><strong>0.00003 <sup>d</sup></strong></td>
<td><strong>0.00001 <sup>e</sup></strong></td>
<td></td>
</tr>
<tr class="even">
<td colspan="2"><em><strong>(see note)</strong></em></td>
<td><em><strong>(see note)</strong></em></td>
<td><em><strong>(see note)</strong></em></td>
<td><em><strong>(see note)</strong></em></td>
<td><em><strong>(see note)</strong></em></td>
<td>--</td>
</tr>
<tr class="odd">
<td rowspan="3"><p><strong>GPL</strong></p>
<p>(General</p>
<p>Population Limit)</p></td>
<td rowspan="3">Civilian population</td>
<td rowspan="3"><p>24-hr/daily, lifetime</p>
<p>time-weighted avg.</p></td>
<td colspan="2"><strong><em>0.0001</em> <sup>b,f,g</sup></strong></td>
<td><em><strong>0.000003<sup>a,c </sup></strong></em></td>
<td><em><strong>0.000003<sup>a,c</sup></strong></em></td>
<td><em><strong>0.000001<sup>a,c</sup></strong></em></td>
<td><em><strong>0.000001<sup>a,b,g</sup></strong></em></td>
<td><em><strong>0.003<sup>a,</sup></strong></em></td>
</tr>
<tr class="even">
<td colspan="2"><strong>0.00002<sup>c</sup></strong></td>
<td><strong>0.000003<sup>d</sup></strong></td>
<td><strong>0.000003<sup>d</sup></strong></td>
<td><strong>0.000001<sup>d</sup></strong></td>
<td><strong>0.0000003<sup>e</sup></strong></td>
<td></td>
</tr>
<tr class="odd">
<td colspan="2"><em><strong>(see note)</strong></em></td>
<td><em><strong>(see note)</strong></em></td>
<td><em><strong>(see note)</strong></em></td>
<td><em><strong>(see note)</strong></em></td>
<td><em><strong>(see note)</strong></em></td>
<td>--</td>
</tr>
</tbody>
</table>

+---------+----------+----+----+----+----+----+----+---------------+
| **Table |          |    |    |    |    |    |    |               |
| F-2:    |          |    |    |    |    |    |    |               |
| C       |          |    |    |    |    |    |    |               |
| hemical |          |    |    |    |    |    |    |               |
| Agent   |          |    |    |    |    |    |    |               |
| Air     |          |    |    |    |    |    |    |               |
| St      |          |    |    |    |    |    |    |               |
| andards |          |    |    |    |    |    |    |               |
| Status, |          |    |    |    |    |    |    |               |
| e       |          |    |    |    |    |    |    |               |
| xisting |          |    |    |    |    |    |    |               |
| and     |          |    |    |    |    |    |    |               |
| p       |          |    |    |    |    |    |    |               |
| roposed |          |    |    |    |    |    |    |               |
| st      |          |    |    |    |    |    |    |               |
| andards |          |    |    |    |    |    |    |               |
| as of   |          |    |    |    |    |    |    |               |
| 9       |          |    |    |    |    |    |    |               |
| /11/02. |          |    |    |    |    |    |    |               |
| POC: V. |          |    |    |    |    |    |    |               |
| Hau     |          |    |    |    |    |    |    |               |
| schild, |          |    |    |    |    |    |    |               |
| USA     |          |    |    |    |    |    |    |               |
| CHPPM** |          |    |    |    |    |    |    |               |
+---------+----------+----+----+----+----+----+----+---------------+
| **Acute |          |    |    |    |    |    |    |               |
| E       |          |    |    |    |    |    |    |               |
| xposure |          |    |    |    |    |    |    |               |
| Gu      |          |    |    |    |    |    |    |               |
| ideline |          |    |    |    |    |    |    |               |
| Levels  |          |    |    |    |    |    |    |               |
| (AEGLs) |          |    |    |    |    |    |    |               |
| (mg/    |          |    |    |    |    |    |    |               |
| m^3^)** |          |    |    |    |    |    |    |               |
+---------+----------+----+----+----+----+----+----+---------------+
| **AEGL  | **       | *  | ** | ** | *  | ** | *  | **Notes/      |
| Level** | Civilian | *H | GA | GB | *G | VX | *  | Status**      |
|         | Popu     | /H | (  | (  | D/ | ** | Le |               |
|         | lation** | D/ | Ta | Sa | GF |    | wi |               |
|         |          | HT | bu | ri | ** |    | si |               |
|         | **       | ** | n) | n) |    |    | te |               |
|         | Exposure |    | ** | ** |    |    | ** |               |
|         | Du       |    |    |    |    |    |    |               |
|         | ration** |    |    |    |    |    |    |               |
+---------+----------+----+----+----+----+----+----+---------------+
| *       | 10 MIN:  | ** | ** | ** | ** | *  | NA | Sulfur        |
| *AEGL - |          | 0. | 0. | 0. | 0. | *0 |    | Mustard AEGLs |
| LEVEL   | 30 MIN:  | 40 | 00 | 00 | 00 | .0 |    | have          |
| 1**     |          | ^  | 69 | 69 | 35 | 00 |    | completed all |
|         | 1 HR:    | i^ | ** | ^  | ^  | 57 |    | stages of     |
| > Po    |          | ** |    | j^ | j^ | ^  |    | established   |
| tential | 4 HR:    |    | ** | ** | ** | j^ |    | review        |
| > minor |          | ** | 0. |    |    | ** |    | process       |
| > dis   | 8HR:     | 0. | 00 | ** | ** |    |    | (AEGL-NAC,    |
| comfort |          | 13 | 40 | 0. | 0. | *  |    | *Federal      |
| > or    |          | ^  | ** | 00 | 00 | *0 |    | Register*,    |
| > not   |          | i^ |    | 40 | 20 | .0 |    | and NRC).     |
| iceable |          | ** | ** | ^  | ^  | 00 |    | They were     |
| > e     |          |    | 0. | j^ | j^ | 33 |    | endorsed by   |
| ffects; |          | *  | 00 | ** | ** | ^  |    | National      |
| > reve  |          | *0 | 28 |    |    | j^ |    | Research      |
| rsible. |          | .0 | ** | ** | ** | ** |    | Council (NRC) |
|         |          | 67 |    | 0. | 0. |    |    | Committee on  |
|         |          | ^  | ** | 00 | 00 | *  |    | Toxicology    |
|         |          | i^ | 0. | 28 | 14 | *0 |    | (COT) as of   |
|         |          | ** | 00 | ^  | ^  | .0 |    | 1/01; Final   |
|         |          |    | 14 | j^ | j^ | 00 |    | values        |
|         |          | *  | ** | ** | ** | 17 |    | scheduled to  |
|         |          | *0 |    |    |    | ^  |    | be published  |
|         |          | .0 | ** | ** | *  | j^ |    | by the NRC in |
|         |          | 17 | 0. | 0. | *0 | ** |    | CY 2002       |
|         |          | ^  | 00 | 00 | .0 |    |    |               |
|         |          | i^ | 10 | 14 | 00 | *  |    | Nerve agents  |
|         |          | ** | ** | ^  | 70 | *0 |    | (G-Agents,    |
|         |          |    |    | j^ | ^  | .0 |    | VX) AEGLs     |
|         |          | ** |    | ** | j^ | 00 |    | were proposed |
|         |          | 0. |    |    | ** | 10 |    | in Fed        |
|         |          | 00 |    | ** |    | ^  |    | Register in   |
|         |          | 83 |    | 0. | *  | j^ |    | May 01;       |
|         |          | ^  |    | 00 | *0 | ** |    | presented as  |
|         |          | i^ |    | 10 | .0 |    |    | INTERIM AEGLs |
|         |          | ** |    | ^  | 00 | ** |    | to the        |
|         |          |    |    | j^ | 50 | 0. |    | NRC-COT for   |
|         |          |    |    | ** | ^  | 00 |    | final review  |
|         |          |    |    |    | j^ | 00 |    | in February   |
|         |          |    |    |    | ** | 71 |    | 2002. On Sept |
|         |          |    |    |    |    | ^  |    | 10 02 they    |
|         |          |    |    |    |    | j^ |    | were          |
|         |          |    |    |    |    | ** |    | finalized --  |
|         |          |    |    |    |    |    |    | after changes |
|         |          |    |    |    |    |    |    | made to VX    |
|         |          |    |    |    |    |    |    | values        |
|         |          |    |    |    |    |    |    | (raised by    |
|         |          |    |    |    |    |    |    | factor of 3,  |
|         |          |    |    |    |    |    |    | based on NRC  |
|         |          |    |    |    |    |    |    | r             |
|         |          |    |    |    |    |    |    | ecommendation |
|         |          |    |    |    |    |    |    | that the      |
|         |          |    |    |    |    |    |    | relative      |
|         |          |    |    |    |    |    |    | potency of    |
|         |          |    |    |    |    |    |    | GB: VX is     |
|         |          |    |    |    |    |    |    | less than     |
|         |          |    |    |    |    |    |    | originally    |
|         |          |    |    |    |    |    |    | proposed).    |
|         |          |    |    |    |    |    |    | *These values |
|         |          |    |    |    |    |    |    | will be       |
|         |          |    |    |    |    |    |    | published in  |
|         |          |    |    |    |    |    |    | Vol 3 of the  |
|         |          |    |    |    |    |    |    | NRC series of |
|         |          |    |    |    |    |    |    | AEGLs         |
|         |          |    |    |    |    |    |    | (anticipated  |
|         |          |    |    |    |    |    |    | early-mid     |
|         |          |    |    |    |    |    |    | 2003)*        |
+---------+----------+----+----+----+----+----+----+---------------+
|         |          |    |    |    |    |    | "  |               |
|         |          |    |    |    |    |    |    |               |
|         |          |    |    |    |    |    | "  |               |
|         |          |    |    |    |    |    |    |               |
|         |          |    |    |    |    |    | "  |               |
|         |          |    |    |    |    |    |    |               |
|         |          |    |    |    |    |    | "  |               |
+---------+----------+----+----+----+----+----+----+---------------+
| ####### | 10 MIN:  | ** | *  | *  | *  | ** | "  |               |
|  AEGL-  |          | 0. | *0 | *0 | *0 | 0. |    |               |
| LEVEL 2 | 30 MIN:  | 60 | .0 | .0 | .0 | 00 | "  |               |
|         |          | ^  | 87 | 87 | 44 | 72 |    |               |
| > Level | 1 HR:    | i^ | ** | ^  | ^  | ^  | "  |               |
| > where |          | ** |    | j^ | j^ | j^ |    |               |
| > more  | 4 HR:    |    | *  | ** | ** | ** | "  |               |
| >       |          | ** | *0 |    |    |    |    |               |
| obvious | 8HR:     | 0. | .0 | *  | *  | ** | "  |               |
| >       |          | 20 | 50 | *0 | *0 | 0. |    |               |
| effects |          | ^  | ** | .0 | .0 | 00 |    |               |
| >       |          | i^ |    | 50 | 25 | 42 |    |               |
|  begin; |          | ** | *  | ^  | ^  | ^  |    |               |
| > Pote  |          |    | *0 | j^ | j^ | j^ |    |               |
| ntially |          | ** | .0 | ** | ** | ** |    |               |
| > im    |          | 0. | 35 |    |    |    |    |               |
| pacting |          | 10 | ** | *  | *  | ** |    |               |
| > fun   |          | ^  |    | *0 | *0 | 0. |    |               |
| ctional |          | i^ | *  | .0 | .0 | 00 |    |               |
| > ab    |          | ** | *0 | 35 | 18 | 29 |    |               |
| ilities |          |    | .0 | ^  | ^  | ^  |    |               |
| > or    |          | *  | 17 | j^ | j^ | j^ |    |               |
| >       |          | *0 | ** | ** | ** | ** |    |               |
| ability |          | .0 |    |    |    |    |    |               |
| > to    |          | 25 | *  | *  | ** | ** |    |               |
| >       |          | ^  | *0 | *0 | 0. | 0. |    |               |
| escape; |          | i^ | .0 | .0 | 00 | 00 |    |               |
| > po    |          | ** | 13 | 17 | 85 | 15 |    |               |
| tential |          |    | ** | ^  | ^  | ^  |    |               |
| >       |          | *  |    | j^ | j^ | j^ |    |               |
| delayed |          | *0 |    | ** | ** | ** |    |               |
| > re    |          | .0 |    |    |    |    |    |               |
| covery. |          | 13 |    | *  | ** | *  |    |               |
|         |          | ^  |    | *0 | 0. | *0 |    |               |
|         |          | i^ |    | .0 | 00 | .0 |    |               |
|         |          | ** |    | 13 | 65 | 01 |    |               |
|         |          |    |    | ^  | ^  | 04 |    |               |
|         |          |    |    | j^ | j^ | ^  |    |               |
|         |          |    |    | ** | ** | j^ |    |               |
|         |          |    |    |    |    | ** |    |               |
+---------+----------+----+----+----+----+----+----+---------------+
| #       | 10 MIN:  | *  | ** | ** | ** | *  | "  |               |
| ######  |          | *3 | 0. | 0. | 0. | *0 |    |               |
| AEGL -  | 30 MIN:  | .9 | 76 | 38 | 38 | .0 | "  |               |
| LEVEL 3 |          | ^  | ** | ^  | ^  | 29 |    |               |
|         | 1 HR:    | i^ |    | j^ | j^ | ^  | "  |               |
| > Life  |          | ** | ** | ** | ** | j^ |    |               |
| > threa | 4 HR:    |    | 0. |    |    | ** | "  |               |
| tening; |          | *  | 38 | ** | ** |    |    |               |
| > level | 8HR:     | *2 | ** | 0. | 0. | *  | "  |               |
| > of    |          | .7 |    | 19 | 19 | *0 |    |               |
| > po    |          | ^  | ** | ^  | ^  | .0 |    |               |
| tential |          | i^ | 0. | j^ | j^ | 15 |    |               |
| >       |          | ** | 26 | ** | ** | ^  |    |               |
| initial |          |    | ** |    |    | j^ |    |               |
| > fata  |          | *  |    | ** | ** | ** |    |               |
| lities. |          | *2 | ** | 0. | 0. |    |    |               |
|         |          | .1 | 0. | 13 | 13 | *  |    |               |
|         |          | ^  | 14 | ^  | ^  | *0 |    |               |
|         |          | i^ | ^  | j^ | j^ | .0 |    |               |
|         |          | ** | j^ | ** | ** | 10 |    |               |
|         |          |    | ** |    |    | ^  |    |               |
|         |          | ** |    | *  | *  | j^ |    |               |
|         |          | 0. | ** | *0 | *0 | ** |    |               |
|         |          | 53 | 0. | .0 | .0 |    |    |               |
|         |          | ^  | 10 | 70 | 70 | ** |    |               |
|         |          | i^ | ^  | ^  | ^  | 0. |    |               |
|         |          | ** | j^ | j^ | j^ | 00 |    |               |
|         |          |    | ** | ** | ** | 52 |    |               |
|         |          | ** |    |    |    | ^  |    |               |
|         |          | 0. |    | *  | *  | j^ |    |               |
|         |          | 27 |    | *0 | *0 | ** |    |               |
|         |          | ^  |    | .0 | .0 |    |    |               |
|         |          | i^ |    | 51 | 51 | ** |    |               |
|         |          | ** |    | ^  | ^  | 0. |    |               |
|         |          |    |    | j^ | j^ | 00 |    |               |
|         |          |    |    | ** | ** | 38 |    |               |
|         |          |    |    |    |    | ^  |    |               |
|         |          |    |    |    |    | j^ |    |               |
|         |          |    |    |    |    | ** |    |               |
+---------+----------+----+----+----+----+----+----+---------------+

**[Notes and References for Table F-2]{.underline}**

( ) numbers in parentheses are from draft sources.

**GREEN** Numbers in Green are currently documented in official Army
regulation/policy/or through DA Headquarter endorsement.

**BLUE** Numbers have been developed/endorsed by non-DoD federal
proponents for Army and non-Army use.

**RED** Numbers are still officially used/endorsed by Army/other
approving entity source but revisions are proposed/underway.

**BLACK** Numbers are final/interim final technical values but are not
yet approved for official implementation by proponent agency.

\*STEL is new proposed standard not previously established.

\*\* Lewisite values are all based on detection; no true IDLH exists (AR
385-61, Table 2-2, 2-3).

**PINK --** regarding ongoing CDC review of AELs and potential changes
to "new" (in black) Army proposed values.

**[REFERENCES:]{.underline}**

a\) DA Pamphlet 40-173: *Occupational Health Guidelines for the
Evaluation and Control of Exposure to Nerve Agents GA, GB, GD, and VX*;
Medical Services, 4 December 1990

b\) AR 385-61: *The Army* *Chemical Agent Safety Program*; Safety; 28
February 1997

c\) USACHPPM Technical Report: *Evaluation of Airborne Exposure Limits
for Sulfur Mustard (HD): Occupational and General Population Exposure
Criteria**, *** Technical Report 47-EM-3767-00**,** November 2000

d\) Mioduszewski et al.; *Evaluation of Airborne Exposure Limits for
G-Agents: Occupational and General Population Exposure Criteria*,
ERDEC-TR-489; April 1998. (and February, 2000 Errata Summary)

e\) Reutter et al.; *Evaluation of Airborne Exposure Limits for VX:
Occupational and General Population Exposure Criteria*; ECBC-TR-074;
February 2000.

f\) DA Pamphlet 40-8: *Occupational Health Guidelines for the Evaluation
and Control of Exposure to Mustard Agents H, HD, and HT*; Medical
Services, August 1991

g\) The Centers for Disease Control (CDC) of the Department of Health
and Human Services (DHHS) 1988. *Recommendations for Protecting Human
Health and Safety Against Potential Adverse Effects of Long-Term
Exposure to Low-Doses of Agents GA, GB, VX, Mustard Agents (H. HT, HD)
and Lewisite (L)*, *Federal Register*, Vol. 53 No 50, page 8504,
Tuesday, March 15, 1988.

h\) March 14 2002, signed by Mr. Raymond J. Fatz, Deputy Assistant
Secretary of the Army (Environment, Safety, and Occupational Health),
addressed to Dr. Paul Joe, Centers for Disease Control (CDC); subject:
comments to Federal Register request for comments, (Jan 8 2002; 67 FR:
894-901).

i\) Final Acute Exposure Guideline Levels (AEGLs) for Sulfur Mustard
(Agent HD): the 6th Interim Report of the COT Subcommittee on AEGLs (Dec
2001), the COT Subcommittee formally states \"The subcommittee concluded
that the revised document conforms with the *Guidelines for Developing
Community Emergency Exposure Levels for Hazardous Substances* (1993) and
*Standing Operating Procedures for Developing Acute Exposure Guideline
Levels for Hazardous Substances* (2001), and that no further
modifications to the document are required.\"  The final values will be
formally published by the National Academy Press, expected out in CY
2002.

j\) Final Acute Exposure Guideline Levels (AEGLs) for G-Agents, Final
Temporary Acute Exposure Guideline Levels (AEGLs) for Nerve Agent VX:
proposed in 66 FR 21940 (May 2, 2001) and upgraded to \"Interim\" and
without any change in June 2001. Per National Research Council (NRC)
Committee on Toxicology (COT) review, and NAC-AEGL meeting \# 26 , 1201
Constitution Ave, NW, Rm 1117, EPA, Washing ton DC, 10 September 2002
G-agent and VX AEGLs were finalized after making changes to interim VX
AEGLs (all raised by factor of 3). This will be documented in meeting
minutes (not yet available) and in the final Nerve Agent AEGL technical
support document, be formally published by the National Academy Press,
expected out in early CY 2003.

k\) USACHPPM Technical Guide 230 Chemical Exposure Guidelines for
Military Personnel, January 2001, updated errata April 02, UPDATE
VERSION with revised chemicals agent AEGLs to be published Jan/Feb 03.

\[blank page\]

# ANNEX G: ANALYTICAL LABORATORIES

There are a number of commercial and government laboratories that are
certified to work with Chemical Warfare Agents (CWAs). These
laboratories would be used when there is a need to analyze samples of
soil, water and vegetation that are suspected to be contaminated with
CWAs. Certified CWA laboratories use CWA standards in order to quantify
their analysis. CWA standards are essential for insuring that results
from one laboratory can be compared to the results of another
laboratory. The U.S. Army has a quality assurance program for the
preparation, analysis, storage, and use of chemical agent standards.
This program is called the Chemical Agent Standard Analytical Reference
Material (CASARM) Program. The CASARM program is managed by SBCCOM which
also certifies the CWA laboratories. (Source: *CSEPP Off-Post Monitoring
IPT Report*, December 1998.)

The facilities listed below were certified (as of 01 December 2001) as
capable of handling chemical warfare agents up to certain thresholds of
quantity and concentration. Particular circumstances at the time of a
chemical event may affect which labs are best suited to the analysis
task, which are available, how quickly they can set up to process
samples, and how quickly they can process samples.

The list below was provided by SBCCOM and is current as of 01 December
2001. Some of the facilities are listed as "Government Facility" or
"Contractor Chemical Agent Facilities," meaning they were certified to
handle neat (i.e. undiluted) chemical agent as well as Research,
Development, Testing and Evaluation (RDTE) dilute solutions of chemical
agent. Other facilities are listed as "Contractor RDTE Solution
Facilities" meaning they were certified to handle only small quantities
of RDTE dilute solutions of chemical agent. (See AR 50-6, Table 6‑1, for
a list of the threshold quantities of RDTE dilute solutions of chemical
agent.)

Since environmental samples originating off-post should not contain
concentrations of agent exceeding RDTE dilute solution thresholds, any
of the facilities listed below should be qualified to handle off-post
recovery samples.

**Government Facility:**

U.S. Army Edgewood Chemical Biological Center

Chemical Evaluation Laboratory

Building E5100

Aberdeen Proving Ground, MD 21010-5424

Phone (410) 436-3555/2772

FAX (410) 436-3003

POC: Mr. Michael Gooden

**Contractor Chemical Agent Facilities:**

Battelle IIT Research Institute

505 King Avenue 10 West 35th Street

Columbus, OH 43201 Chicago, IL 60616

Phone (614) 424-5404 Phone (312) 567-4318

FAX (614) 424‑4905 FAX (312) 567-4286

POC: Dr. Matthew Blais POC: Ms. Jean Graf-Teterycz

Bailment Agreement #DAAD13-00-H-0002 Bailment Agreement
#DAAD13-00-H-0010

Calspan-UB Research Center Midwest Research Institute

P.O. Box 400 425 Volker Boulevard

Buffalo, NY 14225 Kansas City, MO 64110

Phone (716) 592-0008 Phone (816) 753-7600, ext. 1733

FAX (716) 592‑7529 FAX (816) 754-8420

POC: Ms. Meg Stapleton POC: Mr. Chris Bailey

Bailment Agreement #DAAD13-00-H-0008 Bailment Agreement
#DAAD13-00-H-0004

Geomet Technologies, Inc. Southern Research Institute

8577 Atlas Drive 2000 Ninth Avenue South

Gaithersburg, MD 20877 P.O. Box 55305

Phone (301) 417‑9605 Birmingham, AL 35255-5305

FAX (301) 990‑1925 Phone (205) 581-2219

POC: Mr. Frank Kelly FAX (205) 581-2698

Bailment Agreement #DAAD13-00-H-0003 POC: Dr. Ralph Spafford

> Bailment Agreement #DAAD13-00-H-0009

Southwest Research Institute

6220 Culebra Road, P.O. Drawer 28510

San Antonio, TX 78228-0510

Phone (210) 522-5168

FAX (210) 522-3649

POC: Mr. Joseph Brewer

Bailment Agreement #DAAD13-00-H-0007

**Contractor RDTE Solution Facilities:**

Argonne National Laboratory

9700 South Cass Avenue

Argonne, IL 60439-4832

Phone (630) 252-9873

FAX (630) 252-6407

Dr. Hugh J. O'Neill

CMS Field Products/O-I Analytica

2148 Pelham Parkway, Bldg 400

Pelham, AL 35124

Phone (205) 733-6900

FAX (205) 733-6919

POC: Ms. Susanna Keeton

Bailment Agreement #DAAD13-00-H-0005

QuickSilver Analytics, Inc.

1309 Continental Drive, Suite N

Abingdon, MD 21009-2335

Phone: (410) 676-4300

FAX (410) 676-4004

POC: Mr. Rodney D. Hudson

Bailment Agreement #DAAD13-00-H-0006

Truetech, Inc.

680 Elton Ave.

Riverhead, N.Y. 11901-2585

Phone: (631) 727-8600

FAX: (631) 727-7592

POC: Mr. Daniel N. Kohn

Bailment Agreement #DAAA15-89-H-0009

\[blank page\]

# ANNEX H: CLEANUP PROCEDURES UNDER 

# CERCLA AND RCRA

OVERVIEW

This annex describes and compares procedures, rules, and
responsibilities for environmental cleanup under the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act
of 1986 (42 USC § 9601 *et seq*.), and the Resource Conservation and
Recovery Act of 1976 (42 USC § 6901) (RCRA), as amended by the Hazardous
and Solid Waste Amendments of 1984. Both statutes are designed to ensure
that the environmental impacts associated with the release are
thoroughly investigated, and that timely remedial action is taken to
protect the public health, welfare, and the environment. Both statutes
would potentially apply to cleanup of a CAI.

Below are summaries of requirements under each statute and how they
might apply to cleanup after a chemical event. Following those summaries
is a brief discussion of options for negotiating an interagency
agreement to cover cleanup requirements under both statutes.

[Requirements Under CERCLA]{.underline}

Pursuant to Executive Order 12580 (January 23, 1987), the U.S.
Department of Defense (DOD) is authorized to act, consistent with the
National Contingency Plan (NCP), to remove or arrange for the removal
of, and provide for remedial action relating to such release, or to take
any other response measure consistent with the NCP that the DOD deems
necessary to protect the public health or welfare or the environment
(CERCLA Section 104(a)). The DOD is authorized to investigate, monitor,
survey, test, and gather other information as it may deem necessary or
appropriate to identify the existence and extent of the release, the
source and nature of the contamination involved, and the extent of
danger to the public health or welfare or to the environment, including
such planning, legal, fiscal, economic, engineering, architectural, and
other studies or investigations as it may deem necessary or appropriate
to plan and direct response actions (CERCLA Section 104(b)). The DOD has
additional responsibilities set forth in Section 211 of CERCLA, under
the Installation Restoration Program (IRP) (Defense Environmental
Restoration Program). The IRP includes the "correction of environmental
damage (such as detection and disposal of unexploded ordnance) which
creates an imminent and substantial endangerment to the public health or
welfare or to the environment."

Under CERCLA Section 120, the affected site is to be evaluated for
inclusion on the National Priorities List (NPL) under the same
guidelines as a nonfederal facility. If the site is listed on the NPL,
within six months thereof, the DOD, in consultation with the EPA and the
appropriate state authorities, must commence a remedial
investigation/feasibility study (RI/FS) for the site. The Agency reviews
the RI/FS, and within 180 days thereafter, the DOD shall enter into an
interagency agreement with the EPA for the expeditious completion of all
necessary remedial actions. Substantial continuous physical on-site
remedial action shall be commenced at the site not later than 15 months
after completion of the RI/FS (CERCLA Section 121(e)(2)).

If the site is placed on the National Priorities List, the DOD and the
EPA select the final remedial action to carry out in accordance with
Section 121 (relating to cleanup standards) (CERCLA Section 104(c)(4)).
If the site is not on the list, the DOD carries out the remedial action
consistent with SARA Section 211 and the IRP guidance; the DOD, as the
lead agency, selects the final remedial action.

Section 121 requires the remedial action to be in accordance with the
NCP, to the extent possible, and cost-effective, taking into account the
total short- and long-term costs of such alternative actions, including
the costs of operation and maintenance for the entire period during
which such activities will be required, and use permanent solutions and
alternative treatment technologies or resource recovery technologies to
the maximum extent practicable. Under Section 121, the remedial action
selected shall attain a degree of cleanup that assures the levels of
contaminants remaining at the site meet any ARAR, criteria, or
limitation under any federal environmental law, including, but not
limited to, the Toxic Substances Control Act; the Safe Drinking Water
Act; the Clean Air Act; the Clean Water Act; the Marine Protection,
Research, and Sanctuaries Act; or the Solid Waste Disposal Act or any
promulgated standard, requirements, criteria, or limitation under a
state environmental or facility siting law that is more stringent than
any federal standard, requirement, criteria, or limitations (and which
has been identified to the DOD in a timely manner by the affected state)
(CERCLA Section 121(d)). The DOD must work with the appropriate state
environmental agency and the EPA to determine which such standards,
requirement, criteria, or limitations are applicable or relevant and
appropriate to the release site location, the contaminant, or the
proposed method of cleanup.

[Requirements Under RCRA]{.underline}

Requirements under RCRA will depend on local circumstances including
whether the facility has a storage or disposal permit for chemical
weapons operations, or has "interim status" pending approval of such a
permit. For those facilities with permits, requirements will depend on
the particular provisions of the permit. (All of the states with Army
chemical installations (Alabama, Arkansas, Colorado, Indiana, Kentucky,
Maryland, Oregon, and Utah) have obtained EPA authorization to
administer RCRA permits and implement the RCRA corrective action
program.) The following summary represents the most likely circumstances
for must CSEPP sites.

Under RCRA, after immediate emergency response actions have been
performed, the emergency coordinator must "provide for treating,
storing, or disposing of recovered waste, contaminated soil or surface
water, or any other material that results from a release, fire, or
explosion at the facility." (40 CFR 264.56(g).) Note that such material
(for example, contaminated debris, soil or equipment) then becomes
hazardous waste that must be stored, handled and accounted for in the
same manner as other hazardous waste stored at the site.

If operations are shut down as a result of the event, before they may be
restarted, the responsible Army official must notify the state that all
emergency equipment listed in the contingency plan is cleaned and ready
for deployment (i.e., that emergency response capability has been
restored). (40 CFR 264.56(i).)

Within 15 days after the event, a report is due detailing the incident
including identity and quantity of material involved, extent of any
injuries, assessment of actual or potential hazards to human health or
the environment, and estimated quantity and disposition of recovered
materials. (40 CFR 264.56(j).)

At installations where a final disposal facility permit has not yet been
issued (i.e., facilities that are seeking a RCRA permit or are operating
under interim status) corrective actions to clean up any release will be
required as part of the permit approval process, or the permitting
authority may issue an administrative order requiring cleanup. (42 USC
6904(u), 42 USC 6908(h).) Such requirements can include corrective
actions to be performed off-post. (42 USC 6904(v).) However, if there
are difficulties in obtaining permission to perform required cleanup
actions off-post, the Army can appeal to the permitting authority for
relief from those requirements.

On May 1, 1996, the U.S. EPA withdrew its July 27, 1990 Corrective
Action Proposed Rule and introduced a new strategy for promulgating
regulations governing corrective actions. The new proposed rule does not
contain any specific regulations, however, it does include a general
description of the RCRA corrective action process. The process includes
five elements: initial site assessment, site characterization, interim
actions, evaluation of remedial alternatives, and implementation of the
selected remedy.

Approval of the final remedy by the authorizing agency will vary from
state to state. In the absence of final regulations addressing
completion of corrective measures, the new proposed regulation suggests
facilities use the requirements for completion of corrective measures
proposed in 1990 as guidance for developing site-specific procedures for
completion of corrective measures. At a minimum, the public and affected
community should be given notice and an opportunity to comment before a
corrective action implementation is terminated and a facility is
released from its RCRA corrective action obligations. (See Announcement
of Availability and Request for Comment on "Completion of Corrective
Action Activities at RCRA Facilities" Guidance, published by the U.S.
EPA on February 27, 2002 (67 Fed.Reg. 9174)).

At installations where a final disposal facility permit has been issued,
cleanup would be conducted under permit conditions. Temporary storage of
contaminated debris, wreckage, soil, or other contaminated items
resulting from the event may require modification of the permit to
accommodate a Corrective Action Management Unit or Temporary Unit (40
CFR 264.552, 264.553.)

[Use of Interagency Agreements to Reduce Duplication of
Effort]{.underline}

After a chemical event, cleanup requirements under both CERCLA and RCRA
may apply. The potential exists for conflict as to oversight authority
and standards to be applied.

U.S. EPA policy states generally that cleanups under RCRA corrective
action or CERCLA will substantively satisfy the requirements of both
programs unless program differences are sufficiently great to prevent
deferral to the other program (U.S. EPA Memorandum from Steve A. Herman,
Assistant Administrator, Office of Enforcement and Compliance Assurance
Coordination and Elliott P. Laws, Assistant Administrator, Office of
Solid Waste and Emergency Response, to RCRA/CERCLA National Policy
Managers and Regions I-X Agency, re: "Coordination between RCRA
Corrective Action and Closure and CERCLA Site Activities, available at
[http://www.epa.gov/swerffrr/
documents/924memo.htm](http://www.epa.gov/swerffrr/documents/924memo.htm);
see also U.S. EPA Corrective Action for Releases From Solid Waste
management Units at Hazardous Waste management Facilities; Proposed
Rule, 61 Fed.Reg. 19441, May 1, 1996).

U.S. EPA generally favors RCRA oversight of cleanup at sites that are
eligible for, or already listed on, the National Priorities List under
CERCLA. Transfer to RCRA oversight is referred to as "deferral" or
"deletion." This policy was extended to federal facilities in 1997.
(Listing and Deletion Policy for Federal Facilities, interim final
policy statement, November 13, 1997 (62 Fed. Reg. 62523, Nov. 24, 1997,
available at <http://www.epa.gov/swerffrr/documents/40cfr300.htm>.)

U.S. EPA encourages the use of interagency agreements to resolve any
issues and provide for a cooperative effort on cleanup of federal
facilities. There are a number of options for such agreements including
a Federal Facility Agreement, a consent order, and a Facility-Lead
Agreement. What type of agreement is most appropriate and what type of
issues it must address will depend on many factors including the nature
of the release, the permit situation at the installation, and the
presence of other, ongoing installation restoration projects. The
Association of State and Territorial Solid Waste Management Officials
(ASTSWMO) has developed a guide for the transition from federal removal
action to state remediation, entitled *Guide for Coordination of Federal
Removal Actions with State Remedial Activities*, November 2001
(available at the ASTSWMO website,
[http://www.astswmo.org](http://www.astswmo.org/)).

Lastly it should be noted that at any given installation, there may
already be adequate physical arrangements and oversight mechanisms in
place to cover post-event cleanup. While events that lead to protective
actions off-post have been exceedingly rare, leaking munitions per se
are not rare and every chemical storage installation has had to deal
with them. The challenges of a post-emergency cleanup may not be
drastically different in quality from those faced regularly in response
to leaking munitions.

# ANNEX I: MILITARY CLAIMS AUTHORITY

**Processing Claims for Damages under the Federal Tort Claims Act,**

**Military Claims Act and Personnel Claims Act**

This annex contains:

• Summary of authority provided by statutes.

• Discussion of legal limits on statutory authority.

• Overview of the Army Claims Service.

• List of relevant points of contact.

• Citations to relevant statutes, regulations, guidance documents, and
other references for this annex.

**Summary of Statutory Authority**

[Overview]{.underline}

The Federal Tort Claims Act (FTCA), Military Claims Act (MCA) and
Military Personnel and Civilian Employees Claims Act, herein Personnel
Claims Act (PCA) all authorize certain types of claims against the
United States. The FTCA provides relief for injury or damage due to
negligence or willful conduct by federal personnel. It requires
claimants to pursue their claim administratively, with a right to bring
suit in federal court if the claim is denied or not acted upon. The MCA
and PCA also provide for relief against the federal government, but only
via administrative procedure; they do not include a right to judicial
review if the claim is administratively denied. Claims against the U.S.
Army under these three statutes are administered by the U.S. Army Claims
Service (USARCS), a field operating agency of the Office of the Judge
Advocate General headquartered at Fort Meade, MD. The mission of USARCS
is to investigate, process and settle such claims.

[Federal Tort Claims Act]{.underline}

The FTCA waives sovereign immunity for certain tort claims against the
United States and its departments and agencies. Such claims are based on
allegations of negligence or willful misconduct by government personnel.
A plaintiff seeking compensation for injury or damage under the FTCA
must first seek recourse through an administrative process, but if the
government denies the claim or takes no action within a reasonable time
frame, the law provides a right of appeal to the relevant U.S. District
Court (28 U.S.C. §2675). Implementing regulations have been published by
the U.S. Dept. of Justice (28 CFR 14) and the U.S. Army (AR 27-20, 32
CFR 536). In general the FTCA is intended to mimic, in a limited way,
the tort liability of private entities. Claims brought under the FTCA
are evaluated according to the law of the state where they are brought;
for example the state's doctrine on contributory negligence would apply.

[Military Claims Act]{.underline}

The MCA provides an alternative remedy for persons injured by military
activities. To pursue a claim under the MCA, a plaintiff need only
allege injury or damage as a result of noncombat military activities
\[AR 27-20, §3-2 (31 December 1997)\].Unlike the FTCA, under the MCA
there is no need to prove negligence or misconduct \[AR 27-20, §3-5.a(2)
(31 December 1997)\]. However, the MCA provides only an administrative
remedy; there is no right of appeal to a court if the claim is denied.

[Military Personnel and Civilian Employees Claims Act]{.underline}

The PCA allows military personnel and civilian federal government
employees to make claims for loss or damage of personal property that
occurs incident to service. The PCA, like the MCA, provides an
administrative remedy but no right to judicial review. The PCA would
apply, for example, where an Army employee claims that his or her car
was damaged by a hazardous material release while on-post.

**Limits on Statutory Authority**

[Federal Tort Claims Act]{.underline}

The FTCA has been extensively litigated and there is a substantial body
of case law interpretation. There are several limits on FTCA authority
that might come into play in evaluating claims after a chemical accident
or incident (CAI). Some of the major limits are:

• An FTCA claim requires a showing of wrongdoing (negligence or willful
misconduct) on the part of government personnel. If there is no
negligence or misconduct, there is no claim under FTCA. Plaintiffs must
show that their injury was caused by such negligence or misconduct. As a
practical matter, this means that claims based on FTCA authority will
not be payable until the cause of the accident has been investigated and
a determination made that the government is liable.

• The wrongdoing must be attributed to government personnel; wrongdoing
on the part of independent contractors is not covered.

• Negligent conduct by government personnel may be immune from suit if
it was in performance of a "discretionary function." The discretionary
function exception is intended to protect governmental actions that
involve the application of policy discretion or judgement. For example,
a protective action decision would likely be immune from tort suit under
the FTCA (even if it later proved to be ill-advised) because that type
of decision involves weighing various options, balancing considerations
of safety, cost, and obligation to various parties, and applying
judgement under circumstances of uncertainty.

• FTCA claims cannot be based on a strict-liability theory of
ultrahazardous activities or materials; there must be a showing of
negligence or misconduct.

• The FTCA does not authorize advance payments.

• In general a claim must be filed within 2 years of the damage or
injury alleged.

[Military Claims Act]{.underline}

The MCA allows compensation for personal injury or death, or for damage
or loss of real or personal property, caused by military personnel or
civilian DoD employees acting within the scope of their employment, or
that is otherwise "incident to noncombat activities." The types of
damages covered are similar to those covered under the FTCA. Key
limitations on MCA authority are:

• There is no need to prove negligence or misconduct by the Army;
however, plaintiffs still must show a causal link between their injury
and government actions.

• The Secretary of Defense is authorized to pay claims up to \$100,000;
amounts over that figure may be referred to the Secretary of the
Treasury with a recommendation for payment.

• Settlement of a claim under the MCA is final and the claimant waives
any further claims from the event.

• If a claim is denied or settlement cannot be reached, the MCA does not
authorize judicial review.

Advance payments are authorized under the MCA. Authority may be
delegated for advance payments up to \$25,000; advance payments over
\$25,000 up to \$100,000 must be authorized by the Secretary of Defense.
Advance payments do not constitute an admission of liability by the
Army.

[Military Personnel and Civilian Employees Claims Act]{.underline}

The PCA provides relief for a limited range of claimants and types of
damages.

• It provides a remedy only for military personnel and civilian federal
employees; it does not apply to off-post civilians or businesses, or to
government contractor personnel. It might come into play for example if
there were contamination or other damage to items in housing on the
installation, or damage to installation employee's cars.

• It is limited to property claims only; it does not provide for
personal injury or wrongful death actions.

• Claims under the PCA are limited to \$40,000 unless the claim arises
from emergency evacuation or extraordinary circumstances, in which case
the limit goes up to \$100,000.

**Overview of the U.S. Army Claims Service**

USARCS processes claims through a hierarchical structure of offices.
Each level of office has a limited authority to process and settle
claims; claims beyond a certain dollar value must be bumped up to the
next level for approval. The first tier are the local Claims Processing
Offices. A special Claims Processing Office may be set up specifically
to process claims from a disaster. Area Claims Offices are the second,
regional tier. Lastly, decisions on some claims may have to be approved
by a national-level executive such as the Judge Advocate General, the
Secretary of the Army, or the U.S. Attorney General. The exact contours
of settlement authority vary according to which statute controls;
however, the first tier generally can pay out up to \$5,000, the second
tier up to \$25,000, and the higher Army authorities up to \$100,000.
Some high-dollar claims must be referred to the U.S. Attorney General or
the Secretary of the Treasury. There are also "total claims per
incident" limits that may cause claims to be referred to the next tier;
for example, a Claims Processing Office may settle individual FTCA
claims for amounts up to \$5,000, but if the total amount of all claims
from a single incident exceeds \$25,000, then all of the claims must be
approved by the Area Claims Office. \[AR 27-20, Chapter 1, Section II
(Responsibilities); Chapter 2, Section IX (Settlement Procedures); and
§§ 3-6, 4-6 (Settlement Authority).\]

The Army has developed extensive and detailed guidance for the use of
Army lawyers and other personnel involved in processing claims. Army
Regulation (AR) 27-20 (31 December 1997) explains the various statutes
that authorize payment of claims and sets forth the administrative rules
and structure of the Claims Service. In addition, the Army has a
published a 500-page guidebook (DA Pam 27-162, April 1998) addressing
the particulars of how specific types of claims should be investigated
and evaluated for payment. These regulations and guides closely govern
the claims process and help ensure that it is administered uniformly.

It should be noted that, among other things, Section 1-11 of AR 27-20
requires Area Claims Offices to develop disaster claims plans in order
to expedite processing of the numerous claims that might be expected
after a disaster. Such plans provide for augmented legal and
investigative staffing and establishment of special Claims Processing
Offices near the disaster site. It may be expected that a major chemical
weapons event would cause such plans to be implemented.

Standard Form 95, *Claim for Damage, Injury, or Death* is used to submit
claims to the federal government.

**Point of Contact**

[US Army Claims Service Executive Officer]{.underline}

4411 Llewellyn Avenue

Fort Meade, Maryland, 20755

Phone 301 677 7009

Email enrique.mendez@claims.army.mil

**Relevant Statutes, Regulations, Guidance Documents, and Other
References**

[Statutes]{.underline}

*Federal Tort Claims Act*, 28 U.S.C. §§2671-2680.

*Military Claims Act*, 10 U.S.C. §§2731-2739.

*Military Personnel and Civilian Employees Claims Act*, 31 U.S.C. §
3721.

[Claims Regulations and Guidance]{.underline}

Army Regulation (AR) 27-20, *Claims*, 31 December 1997.

U.S. Army, *Claims Against the United States*, 32 CFR 536 (2000)

DA Pam 27-162, *Claims Procedures*, April 1998

U.S. Dept. of Justice, *Administrative Claims under Federal Tort Claims
Act*, 28 CFR 14 (2000).

[Electronic Resources]{.underline}

U.S. Army Claims Service homepage is
<http://www.jagcnet.army.mil/claims/index.nsf?open>.

Army regulations, pamphlets, forms and other policy documents may be
found at the US Army Publishing Agency website,
<http://www.usapa.army.mil/>.

A brief description of the PCA can be found at:

<http://www.setaf.army.mil/osja/OSJA/claims/claims.htm>.

\[blank page\]

# ANNEX J: RESPONSE COSTS UNDER CERCLA

This annex contains:

• Summary of authority provided by statutes.

• Discussion of policy restrictions and options for exercising
authorities.

• List of relevant points of contact.

• Citations to relevant statutes, regulations, guidance documents, and
other references for this annex.

**Summary of Statutory Authority**

Under the Defense Environmental Restoration Program (DERP) statute, the
Secretary of Defense is allocated responsibility for carrying out
response actions under CERCLA for releases of hazardous substances from
any facility or site owned by, leased to, or otherwise possessed by the
United States and under the jurisdiction of the Secretary (10 U.S.C. §
2701(c)). Under CERCLA, a "removal" action includes various actions
taken in response to a release or threatened release of a hazardous
substance, including assessment, monitoring, and cleanup or removal of
the released material, and also including "such other actions as may be
necessary to prevent, minimize, or mitigate damage to the public health
or welfare or to the environment . . . \[including\] measures to limit
access, provision of alternative water supplies, temporary evacuation
and housing of threatened individuals . . ." (42 U.S.C. § 9601(23)).

Under the CERCLA liability provisions (42 U.S.C. § 9607) and the federal
facilities provision (42 U.S.C. § 9620) liability for the costs of
removal will attach to the Army as the owner of the facility, unless the
release is caused solely by an act of God, act of war, or (in some
circumstances) the act of a third party.

Also under CERCLA, a general purpose unit of local government may apply
for reimbursement for emergency response expenses necessitated by a
release or threatened release; however, such reimbursement "shall not
supplant local funds normally provided for response," and the total of
such payments is limited to \$25,000 (42 U.S.C. § 9623).

Note that CERCLA authorizes cleanup of spilled hazardous materials under
the National Contingency Plan (40 CFR Part 300) under the direction of
an On-Scene Coordinator. The National Contingency Plan contains
extensive procedural and substantive requirements concerning the
remediation process. However, that process is outside the scope of this
document.

**Options for Exercising CERCLA Authority**

In regard to compensation for evacuee and state/local government
response costs after a chemical event, there are two separate questions:
(1) Do CERCLA and DERP authorize compensation for this type of expense?
and (2) If so, what funds can be used to pay such compensation?

CERCLA authority has been used to pay compensation for evacuation
expenses associated with cleanup of old chemical munitions found in the
Spring Valley neighborhood of Washington, D.C. However, the Spring
Valley response differs from a chemical weapons stockpile emergency in
that it was an old release from a formerly used site, whereas a chemical
weapons stockpile emergency would involve a currently operating
facility.

\(1\) [Do CERCLA and DERP authorize compensation for evacuees and
state/local governments]{.underline}?

CERCLA and the DERP Act authorize expenditures for measures to protect
public health and safety as part of a removal action. The statutes are
quite general and authorize response action any time there is an actual
or threatened release from a DOD-owned facility. At Spring Valley, this
was interpreted as providing authority for paying evacuee expenses. As
described in LTC Foote's subsequent article in the Army Lawyer,

> The decision to authorize payment of reimbursement expenses opened a
> Pandora\'s box of pragmatic questions on how to implement the policy.
> This largely fell on the Environmental Law Division and the Army Corps
> of Engineers to work out. On 25 January, the Baltimore District of the
> Corps of Engineers announced their provisional policies for
> reimbursing certain expenses incurred by residents evacuated from the
> Spring Valley area during Operation Safe Removal. The policy stated
> that certain expenses would be reimbursed, to include the actual cost
> of hotel rooms, verified by receipts (up to a maximum reimbursement
> rate of \$150 per day) and the actual cost of meals (up to fifty
> dollars per person per day). Costs exceeding fifty dollars per day had
> to be substantiated by written receipt. Other costs would be reviewed
> on a case-by-case basis. To protect against fraud, a list of persons
> who lived in the evacuation area and were affected by the operation
> was prepared (to verify the identity of any person requesting
> reimbursement).

LTC Warren G. Foote, *Operation Safe Removal: Cleanup of World War I Era
Munitions in Washington, D.C.*, The Army Lawyer, August 1994.

With respect to governmental response costs, the EPA regulations contain
numerous restrictions. Superfund money is only to be used for expenses
that are considered to be over and above normal response costs. In
addition, the \$25,000 limit in the statute is interpreted as a cap on
the "total pot." That is, the \$25,000 is the maximum total amount that
will be reimbursed and if there are multiple governmental units
involved, they must determine how to split up the pot and submit a
single joint application for reimbursement (40 CFR §310.9). The
regulations also state that only local governments are eligible for such
payments; state governments are not (40 CFR § 310.6). However, at Spring
Valley, it was determined that this limit did not apply since Superfund
account funds were not being used. (See footnote 62 in Foote 1994.)
Local government expenses were paid using a Cooperative Agreement under
a Defense-State Memorandum of Agreement (DSMOA) (See footnote 64 and
accompanying text in Foote 1994.)

A plausible interpretation of the statute is that the spending limit is
intended to protect the Superfund in instances where expenses cannot be
recovered from a responsible party. The EPA regulations provide that
local governments must attempt to recover from responsible parties
before applying for reimbursement (40 CFR § 310.14). Therefore if the
Army is a responsible party under CERCLA, it may have to pay for the
governmental response costs as such, regardless of the limit in 42
U.S.C. § 9623.

\(2\) [What funds can be used for payment of such
compensation]{.underline}?

DOD and the Army have made a policy decision that DERP funds will be
restricted to paying for expenses associated with releases that are not
from currently operating facilities. This policy is reflected in the
program guidance documents, *DOD Management Guidance for the Defense
Environmental Restoration Program* (March 1998) and *U.S. Army
Environmental Restoration Programs Guidance Manual* (April 1998). Those
documents make it clear that response costs for an emergency at a
currently operating facility are not eligible for use of environmental
restoration funds. For example the Army guidance says in section 1.2.3,
"Activities that are not eligible for ER,A \[Environmental Restoration,
Army\] funding include . . . Cleanup costs of spills associated with
current operations."

Therefore, after a chemical event, CERCLA provides authority to
compensate evacuees and state/local governments for associated emergency
response expenses, as was done at Spring Valley. However, the source of
funds to provide the compensation would likely have to be resolved at
the DA level or above.

**Limits on CERCLA Authority**

It should be noted that CERCLA authority extends only to costs of
removal and remediation, which includes some emergency response costs as
discussed in section 2.1 above. CERCLA does not authorize payments for
other claims such as business losses, personal injury or medical
expenses, or diminished property value (See footnote 59 in Foote 1994.)

Recovery of expenses for medical monitoring or screening has been
litigated extensively. The issue is generally framed as whether medical
screening or monitoring costs for individuals at risk of exposure to a
hazardous release are a legitimate "response" cost, as defined in the
statute, or are tantamount to a medical damages claim, which would not
be cognizable under CERCLA but rather would have to be pursued under the
FTCA or MCA. Federal district courts have split on this issue. See,
e.g., *Brewer v. Ravan*, 680 F. Supp. 1176 (M.D. Tenn. 1988) allowing a
claim for monitoring costs to proceed, but see *Woodman v. United
States*, 764 F. Supp. 1467 (M.D. Fla. 1991) rejecting a similar action.
Two circuit courts have determined that medical monitoring costs are not
recoverable under CERCLA: the Tenth Circuit in *Daigle v. Shell Oil
Co.*, 972 F.2d 1527, 1537 (10th Cir. 1992), and the Ninth Circuit in
*Price v. United States Navy*, 39 F.3d 1011 (9th Cir. 1994).

Further discussion and references on this topic may be found in
Annotation, "What are 'Necessary Costs of Response' Within Meaning of
§107(a)(4)(b) of Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) (42 U.S.C.A. §9607(a)(4)(B))," William B.
Johnson, J.D., 113 A.L.R. Fed. 1; Sessions, Carmen E., "Medical
Monitoring Awards Under CERCLA: Statutory Interpretation Versus
Fundamental Fairness" 8 S.C Envtl. L.J. 81 (Summer 1999); and LaRatta
and Paszamant, "Comment: Diagnosing Medical Monitoring Costs Under
CERCLA: Checking for a Pulse," 7 Vill. Envtl. L.J. 81 (1996).

**Case History: Administration of Evacuee Compensation at Spring
Valley**

At Spring Valley, the U.S. Army Corps of Engineers (USACE) reimbursed
lodging and meal expenses at the full rate of per diem in the locale for
the head of household, plus 2/3 of this rate for each dependent over 12
years of age, plus one-half this rate for each dependent under 12 years
of age. USACE used the entitlements of the Joint Travel Regulation for
permanent change of station as a guide in developing the reimbursement
procedures. They also reimbursed certain miscellaneous expenses as long
as these expenses could be directly related to the evacuation.

The Baltimore District Chief Finance & Accounting Officer had the
authority to approve payment. Payments were generally made within two
weeks from receipt of a properly substantiated reimbursement request.
They also established protest procedures that were resolved at the
Division Counsel level. This appeal system was used when some "odd"
claims were denied.

USACE's authority to pay these claims from DERA funds came from the
Deputy Assistant Secretary of the Army for Installations, Logistics and
Environment. This authority was passed by the Corps of Engineers
headquarters (CEMP-RF), through the North Atlantic Division Commander,
to the Baltimore District Commander. The North Atlantic Division
Commander was designated by HQ as the Final Administrative Appeal
Authority for all evacuation expense reimbursement determinations made
by Baltimore District. The Baltimore District Commander, through his
Chief, Resource Management Office, delegated to the Chief, Finance and
Accounting Branch, the responsibility for receiving, reviewing, and
paying reimbursable expenses found to be reasonable and allocable to the
evacuation requirements at the Spring Valley Site. This delegation noted
that reimbursement of these expenses would be exempt from the terms of
the Prompt Payment Act.

**Points of Contact**

[U.S. Army Judge Advocate General, Legal Services Agency, Environmental
Law Division]{.underline}:

Litigation Center

901 N. Stuart St.

Arlington, VA 22203

703 696 1640

[US Army Corps of Engineers, Office of the Deputy Commanding General for
Military Programs]{.underline}:

Chief, Environmental Restoration Division

GAO Building, 441 G Street, 3rd Floor

Washington, D.C. 20314-1000

202 761 0579

Installation Support Division

GAO Building, 441 G Street, 3rd Floor

Washington, D.C. 20314-1000

202 761 4761

[US Environmental Protection Agency]{.underline}:

Director, Chemical Emergency Preparedness Division

Ariel Rios Bldg.

1200 Pennsylvania Ave.

Washington, D.C. 20460

202 564 8600

Deputy Emergency Coordinator, Chemical Emergency Preparedness Division

Ariel Rios Bldg.

1200 Pennsylvania Ave.

Washington, D.C. 20460

202 564 3434

**Relevant Statutes, Regulations, Guides, and Other References**

[Statutes and Regulations]{.underline}

Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA), 42 U.S.C. §§ 9601 et seq., available at
<http://uscode.house.gov/usc.htm>.

Defense Environmental Restoration Program (DERP) 10 U.S.C. §§ 2701 et
seq., available at

<http://uscode.house.gov/usc.htm>.

Executive Order 12580, *Superfund Implementation* (January 23, 1987),
available at

<http://www.archives.gov/federal_register/codification/executive_order/12580.html>
(see also modifications from subsequent orders, available at
<http://www.nara.gov/fedreg/eo.html#top> ).

EPA regulations implementing CERCLA: 40 CFR Parts 300-373. Also known as
the National Contingency Plan. Available at
<http://www.access.gpo.gov/nara/cfr>.

DODI 4715.7, *Environmental Restoration Program*, April 22, 1996,
available at

<http://www.dtic.mil/envirodod/Policies/DoDInst.htm>.

[DOD and Army Environmental Restoration Regulations, Guidance and
Analysis]{.underline}

AR 200-1, *Environmental Protection and Enhancement*, 21 February 1997,
available at

[http://www.usapa.army.mil](http://www.usapa.army.mil/). Also published
in Code of Federal Regulations, 32 CFR Part 650.

DOD Management Guidance for the Defense Environmental Restoration
Program (September 2001), available at
<http://www.dtic.mil/envirodod/Policies/PDDERP.htm>.

LTC Warren G. Foote, *Operation Safe Removal: Cleanup of World War I Era
Munitions in Washington, D.C.*, The Army Lawyer, August 1994.

[Defense-State Memoranda of Agreement (DSMOA)]{.underline}

Specific criteria, funding information, and services eligible for state
reimbursement via DSMOA are contained in 57 Federal Register 28835,
dated 29 June 1992.

General information on DSMOAs is available at:

<http://hq.environmental.usace.army.mil/programs/dsmoa/dsmoa.html>

Forms and regulations on cooperative agreements are available at:

<http://www.access.gpo.gov/nara/cfr/waisidx_00/32cfr33_00.html>.

DERP annual reports to Congress are available at:
<http://www.dtic.mil/envirodod/Stakeholder/WStates/SI_WSDSMOA.htm>.

[Cases and Articles on Recoverability of Medical Monitoring Costs under
CERCLA]{.underline}

*Brewer v. Ravan*, 680 F. Supp. 1176 (M.D. Tenn. 1988) (allowing a claim
for monitoring costs to proceed)

*Woodman v. United States*, 764 F. Supp. 1467 (M.D. Fla. 1991)
(rejecting argument in *Brewer*).

*Daigle v. Shell Oil Co.*, 972 F.2d 1527, 1537 (10th Cir. 1992) (denying
medical monitoring costs).

*Price v. United States Navy*, 39 F.3d 1011 (9th Cir. 1994) (denying
medical monitoring costs).

Annotation, "What are 'Necessary Costs of Response' Within Meaning of §
107(a)(4)(b) of Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) (42 U.S.C.A. § 9607(a)(4)(B))," William B.
Johnson, J.D., 113 A.L.R. Fed. 1.

Sessions, Carmen E., "Medical Monitoring Awards Under CERCLA: Statutory
Interpretation Versus Fundamental Fairness" 8 S.C Envtl. L.J. 81 (Summer
1999).

LaRatta and Paszamant, "Comment: Diagnosing Medical Monitoring Costs
Under CERCLA: Checking for a Pulse," 7 Vill. Envtl. L.J. 81 (1996).

\[blank page\]

# ANNEX K: DISASTER ASSISTANCE UNDER 

# THE STAFFORD ACT

This annex contains:

• Overview of relevant legislation.

• Summary of benefits available to individuals, businesses and
state/local governments.

• Summary of procedure for requesting Presidential declaration of
emergency or major disaster.

• Summary of criteria used for evaluating such requests.

• FEMA points of contact.

• Citations to relevant statutes, implementing regulations, guidance
materials, and other sources of information.

**Overview of Legislation**

The Robert T. Stafford Disaster Relief and Emergency Assistance Act,
P.L. 93‑288, as amended, authorizes the President (FEMA per Executive
Order 12148 as amended) to provide financial and other forms of
assistance to individual households, state and local governments, and
certain private nonprofit organizations following Presidentially
declared major disasters and emergencies. The Stafford Act describes
generally the declaration process, the types and extent of assistance
that may be provided and fundamental eligibility requirements.

The Disaster Mitigation Act of 2000 (P.L. 106-390) (DMA) made numerous
changes in federal policy and programs for disaster preparedness and
response. The DMA increased emphasis on mitigation and disaster
prevention, and also made changes to disaster-response programs intended
to streamline federal assistance.

**Assistance Available to Individuals, Businesses and State/Local
Governments**

The FEMA disaster assistance programs are primarily activated in natural
disasters such as floods, hurricanes, tornadoes, winter storms,
earthquakes and wildfires, where widespread physical damage to homes,
businesses and community infrastructure is a direct result of the
disaster. A chemical weapons emergency would likely have a different set
of consequences. An evacuation might be required, causing residents to
incur temporary housing costs and disrupting local businesses. However,
direct physical damage to the evacuated area is considered unlikely.
Nevertheless, damage requiring repair or replacement of homes and
buildings might occur as an indirect consequence of their being
unoccupied, or due to a failure of utilities or emergency services. For
example there might be fire damage that is caused or exacerbated by the
inability to send firefighters into a restricted area.

Most of the information for this section was compiled from primary
sources (statutes and regulations), the FEMA publication *A Guide to the
Disaster Declaration Process and Federal Disaster Assistance*, and the
Congressional Research Service publication *FEMA and Disaster Relief*
(1998). (See references section below for citations.)

Assistance under the Stafford Act requires a Presidential declaration; a
summary of rules and procedures for such declarations is given below.

**Activation of the Federal Response Plan**

In addition to administering the financial assistance programs for
individuals and state/local governments described below, FEMA
coordinates emergency response efforts by other federal agencies
pursuant to the Stafford Act. The Federal Response Plan (FRP) describes
federal agency roles and assistance that can be provided after the
President declares an emergency or major disaster. The FEMA Director
appoints a Federal Coordinating Officer to coordinate federal efforts
under the FRP. According to the introduction to the FRP, it "covers the
full range of complex and constantly changing requirements following a
disaster: saving lives, protecting property, and meeting basic human
needs (response); restoring the disaster-affected area (recovery); and
reducing vulnerability to future disasters (mitigation). The FRP does
not specifically address long-term reconstruction and redevelopment."
(FRP Basic Plan, I.B.2.)

**Housing and Financial Assistance for Individuals**

Residents displaced by a disaster may be eligible for assistance with
temporary housing. Assistance can include money to reimburse temporary
lodging expenses or rent payments, and/or to help with repair or
replacement of homes that were damaged (42 U.S.C. §5174). Only uninsured
losses are covered. Temporary housing assistance is limited to 18 months
at the most.

Funding is also available for "necessary expenses and serious needs of
disaster victims that are not met through insurance or other disaster
programs." (P.L. 106-390, §206(a).) This can include payments for
medical, dental and funeral expenses, personal property, and
transportation.

FEMA currently provides housing expenses through one program (the
Disaster Housing Assistance program) and other assistance through
another (the Individual and Family Grant program). Effective May 2002,
the DMA repeals the preexisting housing assistance and individual and
family grant programs, replacing them with a single Individual
Assistance Program (IAP) that combines housing assistance and financial
assistance for other disaster-related expenses. As of the date of this
document, implementing regulations for the new IAP have not yet been
published either in draft or final form.

**Loans for Individuals, Farms and other Businesses**

*Small Business Administration Disaster Loans.* The Small Business
Administration (SBA) can make federally subsidized loans to repair or
replace homes, personal property, or businesses that sustain damages not
covered by insurance (15 U.S.C. §636(b)). Types of disaster loans
provided by SBA include: (1) home disaster loans, to homeowners and
renters to repair or replace disaster-related damages to homes or
personal property; (2) business physical disaster loans, to business
owners to repair or replace disaster-damaged property, including
inventory and supplies; and (3) economic injury disaster loans, which
provide capital to small businesses and to small agricultural
cooperatives to assist them through the disaster recovery period.

*Farm Service Agency Loans.* The U.S. Department of Agriculture can make
loans of up to \$500,000 for the repair or replacement of damaged farm
and aquaculture property and supplies (7 U.S.C. §1961). Assistance is
authorized after a Presidential declaration of a major disaster or upon
declaration by the Secretary of Agriculture. Loans are provided at a
4.5% interest rate for no more than 20 years for production (up to 80%
of loss) and no more than 40 years for property (up to 100% of loss).
Assistance is provided only to those without access to credit.

**Other Available Assistance to Individuals**

*Unemployment Assistance.* Disaster unemployment assistance authorized
by Section 410 of the Stafford Act (42 U.S.C. §5177) is administered
through the U.S. Department of Labor. It is available for persons
unemployed as a result of the disaster. The assistance cannot exceed
compensation limits established by the state and continues to be
provided until the individual is reemployed, but for not more than 26
weeks.

*Legal Services.* Legal services which include legal advice, counseling,
and representation in non fee-generating cases may be provided to
low-income individuals who require them as a result of a major disaster.
Authorized by Section 415 of the Stafford Act, 42 U.S.C. §5182.

*Food and Food Coupons.* Section 412 of the Stafford Act (42 U.S.C.
§5179) authorizes the President to distribute food stamps and surplus
commodities to low-income households affected by a major disaster.

*Crisis Counseling.* Counseling provided through the National Institute
of Mental Health may be available to individuals or groups coping with
mental or emotional crises (42 U.S.C. §5183).

*Gifts and Bequests (Cora Brown Fund).* Other assistance may be provided
from the Cora Brown Fund administered by FEMA, for needs of disaster
victims that cannot be met through governmental or other organizational
programs. The fund was established by bequest; administrative
regulations may be found at 44 CFR §206.181.

**Assistance to State/Local Governments**

The Public Assistance Program (PAP) provides funds to state and local
units of government and to certain non-profit organizations to meet
immediate needs of communities and to repair or rebuild public buildings
and infrastructure. FEMA regulations associated with the PAP are found
at 44 CFR 206.200 - 206.399.

*Grants.* Seven program areas have been established by FEMA to
administer infrastructure assistance authorized in Title IV of the
Stafford Act. These include: (1) Debris removal (Category A); (2)
Protective measures (Category B); (3) Roads and bridges (Category C);
(4) Water control facilities (Category D); (5) Public buildings
(Category E); (6) Public utilities (Category F); and (7) Other (Category
G).

Funding and technical assistance is provided to state and local
governments and certain private nonprofit institutions for the repair or
replacement of facilities damaged or destroyed by the disaster. This
assistance is generally in the form of a grant for not less than 75% of
the cost of restoration (and hazard mitigation required by FEMA) of
facilities, including schools. FEMA also can provide assistance for
emergency protective measures, debris removal, emergency communications,
and emergency public transportation. Authorized in Sections 403, 406,
and 407 of the Stafford Act, 42 U.S.C. §§5170b, 5172, and 5173.

*Community Disaster Loans.* In event of a major disaster, the President
is authorized to make loans to "any local government which may suffer a
substantial loss of tax and other revenues . . . and has demonstrated a
need for financial assistance in order to perform its governmental
functions." (42 U.S.C. §5184.) Applicable FEMA regulations are found at
44 CFR 206.360 - 206.367. The loan is limited to 25% of the community's
operating budget for the fiscal year in which the disaster occurs. Loan
repayment may be canceled if tax revenues do not recover within three
years. The DMA establishes a \$5 million cap on community disaster
loans. (P.L. 106-390, §207.)

**Hazard Mitigation**

*Hazard Mitigation Grant Program (HMGP).* Section 404 of the Stafford
Act (42 U.S.C. §5170c) established a program to fund mitigation measures
after a disaster. The purpose of the program is to prevent or minimize
recurrence of similar disasters in the future. FEMA can contribute 75%
of the cost of eligible mitigation measures. Total funding is limited to
15% of the estimated grants for individual assistance programs and
public assistance projects. Under the DMA, this is raised to 20% if the
state has an approved hazard mitigation plan in place at the time of the
disaster. (P.L. 106-390, §104.)

Eligibility for the HMGP is the same as for the public assistance
program: state and local governments, Indian tribes and tribal
organizations, and certain private non-profit organizations and
institutions. The state, as grantee under the program, has
responsibility for overseeing the funded projects.

**Procedure for Requesting Presidential Declarations**

Assistance under the Stafford Act depends on a Presidential declaration
of necessity. The Act establishes two categories of Presidential
declarations: emergency and major disaster.

**Emergency vs. Major Disaster**

An *emergency declaration* can be requested by the governor under 42
U.S.C. §5191(a) or can be initiated by the President under 42 U.S.C.
§5191(b) if the emergency situation is "one for which the primary
responsibility rests with the United States." (42 U.S.C. §5191.) Federal
assistance authority for emergencies is limited and does not include all
of the programs described in Section 2 above; however, it does include
temporary housing assistance and assistance to state/local governments
with provision of food, medicine, and emergency response. Overall
expenditures are limited to \$5 million unless the President reports to
Congress that additional assistance is needed.

The first use of the President's authority to self-initiate an emergency
declaration was in 1995 after the attack on the Murrah federal building
in Oklahoma City; an emergency was declared by the President on April
19, within 7 hours of the explosion.

A *major disaster declaration* authorizes assistance of various kinds,
including long-term housing, disaster unemployment assistance,
individual and family grant programs, grants to restore public
facilities, community disaster loans, and others, with no overall
financial limit. Unlike a declaration of emergency, the President may
not initiate a declaration of major disaster; the state's Governor must
request it (42 U.S.C. §5170). Procedures for this request are outlined
below.

President Clinton declared a major disaster in Oklahoma City one week
after the Murrah building bombing, following a request from the Governor
of Oklahoma.

**Procedure for Requesting Declaration**

FEMA regulations outline the procedure for requesting relief assistance.
Procedures for requesting a Presidential declaration of *emergency* are
found in 44 CFR 206.35. A request may come from the governor or, for
emergencies where the primary responsibility rests with the federal
government, from the FEMA Regional Director, or another federal agency
acting through the FEMA Regional Director. Procedures for requesting a
Presidential declaration of a *major* *disaster* are found in 44 CFR
206.36. A request for a major disaster declaration must come from the
governor and should be submitted to the appropriate FEMA Regional
Director.

The statute and regulations lay out requirements for the content of
requests for declarations. In general they must include a statement to
the effect that the Governor has activated the state response plan, that
the emergency is beyond the state's capabilities to effectively respond,
and that federal assistance is needed. The Governor's request for a
major disaster declaration must include a pledge to pay a share of the
costs incurred. See discussion of cost-sharing below.

Requests for declarations are to be sent to the local FEMA regional
office. FEMA normally evaluates them at the regional level and then runs
them up the chain to the FEMA Director and ultimately the President.
FEMA procedures for processing requests for declarations are set out in
44 CFR 206.37. It should be noted that these procedures do not limit the
discretion of the President; in view of the federal nature of a chemical
stockpile emergency, some or all of those procedural steps might be
short-circuited in the actual event.

**Criteria for Evaluating a Request for Declaration**

FEMA has published criteria for evaluating requests for a major disaster
declaration at 44 CFR 206.48. There are separate criteria for the Public
Assistance Program and the Individual Assistance Program. Factors
considered in determining the need for assistance under the PAP include
estimated cost per capita for the state (with a benchmark of
\$1/person); presence of concentrated local impacts; insurance coverage;
hazard mitigation (i.e. were available means used to mitigate damage);
other recent disasters; and availability of assistance from other
federal programs. Factors considered in determining the need for
assistance under the IAP include concentration of damages; trauma;
presence of affected special populations; insurance coverage; assistance
available from other sources; and average dollar costs per affected
individual.

These criteria do not limit the discretion of the President; if there is
a chemical event the President may choose to issue a declaration whether
or not the criteria are met.

**Cost-sharing**

Stafford Act assistance is usually provided on a cost-share basis in
which the federal government picks up the majority of the cost, but
requires a significant contribution from the affected State. The Act
provides generally that the federal share for emergency assistance under
a Presidential emergency declaration or major disaster declaration will
be not less than 75% \[42 U.S.C. §§5170b(b), 5193(a)\]. The text of the
declaration usually includes a percentage for cost sharing. For example,
after the Murrah building bombing in Oklahoma City, the President's
emergency declaration dated April 19, 1995 provided for assistance at a
100% federal rate. A recent declaration of major disaster by President
Bush due to severe storms and flooding in Alabama specified a 75%
federal cost share (66 Fed. Reg. 15716 (March 20, 2001)). Certain
administrative costs associated with applying for and overseeing grants
are reimbursed at a 100% level.

**FEMA Points of Contact**

FEMA HQ:

FEMA General Counsel

500 C St. SW, Washington, D.C. 20472

\(202\) 646 3900

FEMA Regional Offices:

Region I \[Connecticut, Maine, Massachusetts, New Hampshire, Rhode
Island, Vermont\]

Federal Emergency Management Agency

J.W. McCormack Post Office and Court House, Room 442

Boston, MA 02109-4595

\(617\) 223-9450

Region II \[New Jersey, New York, Puerto Rico, Virgin Islands\]

Federal Emergency Management Agency

26 Federal Plaza, Room 1337

New York, NY 10278-0002

\(212\) 225-7209

Region III \[Delaware, District of Columbia, Maryland, Pennsylvania,
Virginia, West Virginia\]

Federal Emergency Management Agency

615 Chestnut Street B Sixth Floor

Philadelphia, PA 19106

\(215\) 931-5608

Region IV \[Alabama, Florida, Georgia, Kentucky, Mississippi, North
Carolina, South Carolina, Tennessee\]

Federal Emergency Management Agency

3003 Chamblee-Tucker Road

Atlanta, GA 30341

\(770\) 220-5200

Region V \[Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin\]

Federal Emergency Management Agency

536 South Clark St.

Chicago, IL 60605

\(312\) 408-5501

Region VI \[Arkansas, Louisiana, New Mexico, Oklahoma, Texas\]

Federal Emergency Management Agency

Federal Regional Center, 800 N. Loop 288

Denton, TX 76201-3698

\(940\) 898-5104

Region VII \[Iowa, Kansas, Missouri, Nebraska\]

Federal Emergency Management Agency

2323 Grand Blvd, Suite 900

Kansas City, MO 64108-2670

\(816\) 283-7061

Region VIII \[Colorado, Montana, North Dakota, South Dakota, Utah,
Wyoming\]

Federal Emergency Management Agency

Denver Federal Center, Building 710, Box 25267

Denver, CO 80225-0267

\(303\) 235-4812

Region IX \[American Samoa, Arizona, California, Guam, Hawaii, Nevada,
Commonwealth of the Northern Mariana Islands, Federated States of
Micronesia, Republic of the Marshall Islands\]

Federal Emergency Management Agency

111 Broadway, Suite 1200

Oakland, CA 94607-4052

\(510\) 923-7100

Region X \[Alaska, Idaho, Oregon, Washington\]

Federal Emergency Management Agency

Federal Regional Center, 130 228^th^ Street, SW

Bothell, WA 98021-9796

\(425\) 487-4604

**Relevant Statutes, Regulations, Guidance, and Other References**

[Statutes and Regulations]{.underline}

Stafford Act, 42 U.S.C. §§5121 et seq., available at
<http://uscode.house.gov/usc.htm>.

Disaster Mitigation Act of 2000, Pub. Law 106-390, available at

<http://uscode.house.gov/usc.htm>.

Small Business Administration authority for disaster loans is found at
15 U.S.C. §636(b).

U.S. Dept. of Agriculture authority for disaster loans to farms is found
at 7 U.S.C. §1961.

FEMA regulations for disaster assistance are found at 44 CFR Part 206.

The Federal Response Plan is available at
<http://www.fema.gov/rrr/frp/pdfs.shtm>.

[FEMA Guidance and Summary Materials]{.underline}

The Legal room of the FEMA Online Library
(<http://www.fema.gov/library/lib10.htm>) contains links to the text of
the Stafford Act, Title 44 of the Code of Federal Regulations, and a
Powerpoint briefing about the Disaster Mitigation Act of 2000.

Information about individual and public assistance, and guidance on the
disaster declaration process, can be obtained from the FEMA Response and
Recovery Directorate webpage, <http://www.fema.gov/rrr/>.

[Other References]{.underline}

Keith Bea, Congressional Research Service, *FEMA and Disaster Relief*
(1998), available (for a fee) at
<http://www.pennyhill.com/emergencymanagement/97-159gov.html>.

Oklahoma Department of Civil Emergency Management, *After Action Report:
Alfred P. Murrah Federal Building Bombing, 19 April 1995 in Oklahoma
City, Oklahoma*, available at
<http://www.odcem.state.ok.us/archives/fema/1048/aar-cove.htm>.

\[blank page\]

# ANNEX L: STATE EMERGENCY PREPAREDNESS STATUTES

Each State has a statute addressing emergency management. The statutes
generally specify that the governor, and at the local level, a top
county or municipal executive, may exercise particular emergency powers,
including the power to declare a state or local "state of emergency" and
implement protective actions. Emergency services statutes also typically
assign responsibility for emergency planning and preparedness to
particular officials. Following is a state-by-state summary of these
statutes for the ten CSEPP community states.

**Alabama**

Emergency management powers and responsibilities are addressed in the
Code of Alabama, Title 31, Chapter 9, Sections 31-9-1 to 31-9-24. The
chapter establishes the Alabama Emergency Management Agency (AEMA),
whose director is to "coordinate the activities of all organizations of
emergency management within the state, and . . . maintain liaison with
and cooperate with major commanders of the armed forces within the
state, the state department of public safety, the state military
department and with emergency management agencies and organizations of
other states and of the federal government . . . ." (Section 31-9-4(d).)
AEMA's functions include medical and health services, rescue,
communications, "radiological, chemical and other special weapons of
defense," evacuation, emergency transportation, and other related
functions.

The statute empowers the governor of Alabama to prepare a comprehensive
emergency plan and program to be coordinated with federal and local
government plans and programs to the extent possible. In a disaster, the
governor may declare a state of emergency during which the governor may
exercise various emergency powers, including the power to assume direct
operational control of all emergency management forces in the state,
"provide for and compel the evacuation of all or part of the population
from any stricken or threatened area . . .," control traffic, seize
property for emergency response use, and perform "such other functions,
powers and duties as are necessary to promote and secure the safety and
protection of the civilian population." (Section 31-9-8.) The statute
also authorizes creation of local emergency management organizations by
political subdivisions of the state. The local emergency management
organizations may prepare local plans, in accordance with the state
plan, establish local emergency operation centers, and otherwise prepare
for and respond to disasters. However, there does not appear to be a
local equivalent of the governor\'s power to declare a state of
emergency. Thus, any compulsory aspects of response apparently must be
initiated at the state level.

**Arkansas**

Emergency management in Arkansas is addressed in the Arkansas Code of
1987 Annotated, Title 12, Chapter 75. Sections 12-75-109 to 111
establish the Arkansas Office of Emergency Management (OEM) and describe
its powers and duties. The OEM is charged with preparation and
maintenance of the State Disaster Plan; coordination with the federal
government, other states, and local governments; and review of local
disaster plans and other emergency management activities. The statute
also requires that local OEMs be maintained by each county and by those
municipalities that the governor determines need one. Each local OEM
must prepare a local emergency response plan and submit it to the state
OEM for approval. There is also provision for inter-jurisdictional
plans. Two or more local units of government may agree to jointly
operate an OEM, or the governor may designate an inter-jurisdictional
emergency planning district, combining two or more counties.

In a disaster, the governor is empowered to issue a declaration of
disaster emergency, which activates all aspects of the disaster plan.
Declaration of a disaster emergency enables the governor to exercise
various emergency powers, including direct control of the resources of
state and local agencies, suspension of regulatory compliance, and
seizure of property (subject to compensation) needed for response. The
governor may also "direct and compel the evacuation of all or part of
the population from any stricken or threatened area . . .; prescribe
routes, modes of transportation, and destinations in connection with
evacuation; \[and\] control ingress and egress to and from a disaster
area . . . ." (Section 12-75-114.) The principal executive officer of a
local jurisdiction may declare a local disaster emergency, thereby
activating the local plan. During the local disaster emergency, the
principal executive officer may exercise powers similar to the
governor's emergency powers within the local jurisdiction.

**Colorado**

Emergency management in Colorado is addressed in the Colorado Revised
Statutes (C.R.S.), Title 24, Article 32 (Department of Local Affairs),
Parts 21 (Office of Disaster Emergency Services); 22 (Compensation
Benefits to Volunteer Civil Defense Workers); 23 (Civil Defense
Liability‑ Public or Private); 24 (Evacuation of School Buildings for
Civil Defense); 25 (Disaster Relief); and 26 (Colorado Emergency
Planning Commission).

The statute establishes the Office of Emergency Management (OEM) within
the Department of Local Affairs, division of local government (C.R.S.
Section 24-32-2105). OEM is responsible for developing and maintaining
the state disaster plan and for providing assistance to local
governments with their disaster plans.

The statute provides for special executive powers in the event of an
emergency: "A disaster emergency shall be declared by executive order or
proclamation of the governor if the governor finds a disaster has
occurred or that this occurrence or the threat thereof is imminent."
(C.R.S. Section 24-32-2104.) Such a declaration activates the state,
local, and inter-jurisdictional emergency plans and confers a variety of
special powers upon the governor. The governor may compel evacuation,
control access to affected areas, provide for temporary emergency
housing, and perform other response actions. The Colorado statute also
provides for the governor to be advised by a Disaster Emergency Council
of state government officials and agency heads.

The principal executive officer of a political subdivision may declare a
local disaster emergency, activating local and inter-jurisdictional
emergency plans. (C.R.S. Section 24-32-2109.)

**Illinois**

Emergency management in Illinois is covered by the Illinois Emergency
Management Agency Act, P.A. 85-1027 (1988), as amended by P.A. 87-168
(1991); codified in the Illinois Compiled Statutes, 20 ILCS 3305.

Section 5 of the Act establishes the Illinois Emergency Management
Agency (IEMA) and describes the agency\'s powers and duties. IEMA is to
"coordinate the overall emergency management program of the State,"
including planning, assistance, and oversight of local agency planning
and arrangements for staff and resources that can be called upon when
needed for emergency response. (20 ILCS 3305/5.) The Act also provides
for a local emergency services and disaster agency for each political
subdivision of the state (Section 10). Counties are the primary level
for local agencies, except for municipalities with populations greater
than 500,000. The Act also provides for mutual aid agreements between
political subdivisions (Section 13) and for creation of mobile support
teams that can be activated to augment agency response efforts in an
emergency (Section 8).

In a disaster, the governor may issue a disaster proclamation that
activates the state emergency operations plan. The disaster proclamation
also enables the governor to exercise special emergency powers for up to
30 days, including use of state resources as necessary to cope with the
disaster, temporary or permanent seizure of property (subject to
compensation), recommendation of evacuation and control of ingress and
egress to and from a disaster area, and arrangements for emergency
housing (Section 7). At the local level, the principal executive officer
of a political subdivision may declare a local disaster that activates
the local emergency operations plan (Section 11). Local disaster
declarations are limited to seven days, except upon consent of the
political subdivision\'s governing board.

**Indiana**

The Indiana Code, Title 10, Article 4, Chapter 1 and Article 8, Chapter
2 create the Indiana State Emergency Management Agency, which is
responsible for preparing and maintaining a state disaster plan,
managing all aspects of the state disaster preparedness program, and
coordinating with other governmental bodies. The Code also requires that
each political subdivision within the state be served by a local
department of civil defense. Local governments may combine to form
inter-jurisdictional disaster agencies. The governor may also require a
political subdivision to establish and maintain a disaster agency
jointly with one or more others, but only "with the concurrence of the
affected political divisions" (Section 10-4-1-10). Local disaster
agencies may prepare for emergencies by recruiting response personnel,
establishing emergency operations centers, and arranging for emergency
supplies. The Code also authorizes state and local emergency departments
to form mutual aid agreements.

In an actual or imminent disaster, the governor may declare a state of
disaster emergency. During the state of disaster emergency, the governor
may exercise emergency powers, including the powers to use of all state
and local government resources to cope with the emergency, commandeer
private property (subject to compensation), assist in the evacuation of
all or part of the population from a stricken or threatened area,
prescribe evacuation routes, control access to stricken areas, and
provide for temporary emergency housing. There is no provision for
declaration of emergency at the local level.

**Kentucky**

The Kentucky legislature revamped the emergency management law in 1998.
Emergency management is now addressed in the Kentucky Revised Statutes,
Chapters 39A through 39F. Responsibility for state emergency planning
and management is delegated to the Division of Emergency Management. At
the local level, each "city, county, urban-county or charter county
government of this Commonwealth shall create, support, and maintain a
local emergency management agency, which shall serve the public safety
interest of the local government within

the territorial boundaries of the city or county where the agency is
created." (K.R.S. Sec. 39B.010.) Local governments may combine in
establishing joint emergency organizations. Local governments are
authorized to expend funds for emergency planning and preparation,
including establishing local emergency operations centers, stockpiling
supplies, and employing emergency response personnel.

In an actual or threatened emergency, the governor may declare that a
state of emergency exists, activating certain supplemental powers on the
part of the governor. During the state of emergency, the governor may
direct and control all emergency response forces, may seize (subject to
compensation) certain types of private property needed for the response
effort, including means of transportation and communication, stocks of
fuel, food, clothing and medical supplies, and facilities such as
buildings and plants. The governor may also "exclude all nonessential
personnel" from the scene of the emergency, declare curfews, request
assistance from the federal government, and "perform and exercise such
other functions, powers, and duties as may be deemed necessary to
promote and secure the safety and protection of the civilian
population." (K.R.S. Sec. 39A.100.)Similar powers are accorded to the
local chief executive upon his or her declaration of a local state of
emergency.

**Maryland**

The Maryland Emergency Management Agency Act is codified in the
Annotated Code of the Public General Laws of Maryland, Article 16a,
Sections 1-36. The Act establishes the Maryland Emergency Management
Agency (MEMA), which is responsible for carrying out the state emergency
management program, including emergency planning and coordinating
implementation of response measures in an emergency. There is also an
Emergency Management Advisory Council, appointed by the Governor, to
advise the Governor on matters pertaining to emergency management.

The Governor may declare a state of emergency, which authorizes special
emergency powers for up to 30 days. Upon declaration the Governor may
(1) Suspend the provisions of any statute, or of any rule or regulation
of any State or local agency; (2) Direct and compel the evacuation of
all or part of the population from any stricken or threatened area
within the State;

\(3\) Set evacuation routes and modes of transportation to be used
during an emergency;

\(4\) Direct the control of ingress and egress to and from an emergency
area, the movement of persons within the area, and the occupancy of
premises therein; (5) Authorize the utilization of any private property,
in which event the owner of the property shall be compensated for

its use and for any damage to the property; (6) Provide for temporary
housing; and (7) Authorize the clearance and removal of any debris and
wreckage. (Article 16a, Sec. 6a.)

At the local level, "each political subdivision of \[the\] state is to
establish a local organization for emergency management in accordance
with the state emergency plan and program and shall participate in
federal programs for emergency management." (Article 16a, Sec. 7.) The
directors of the local organizations are appointed by the governor upon
recommendation of the local mayor, executive, or governing body. The
local chief executive may declare a local state of emergency, valid for
up to 7 days. As provided in the statute, "The effect of a declaration
of a local state of emergency is to activate the response and recovery
aspects of any and all applicable local state of emergency plans and to
authorize the furnishing of aid and assistance thereunder." (Article
16a, Sec. 6C.)

**Oregon**

The legal framework for emergency management in Oregon is described in
the Oregon Revised Statutes (O.R.S.), Chapter 401, Sections
401.015-401.990. The governor is allocated responsibility for the state
emergency services system, assisted by the state Office of Emergency
Management (OEM) within the Department of State Police. (O.R.S. Sec.
401.260.) The OEM is responsible for coordinating the activities of all
public and private emergency services agencies within the state and for
establishing a liaison with other states and the federal government.

The governor may declare a state of emergency at the request of a county
governing body or after determining that an emergency has occurred or is
imminent. The declaration must describe the geographical area covered,
which must be no larger than necessary to effectively respond to the
emergency. During a declared emergency, the governor may exercise direct
control over state agency resources and operations to effect response
and recovery measures. The governor may also assume control of local law
enforcement agencies, direct all rescue and salvage work, close roads
and limit access to the emergency area, arrange for temporary housing,
and "do all things deemed advisable and necessary to alleviate the
immediate conditions." (O.R.S. Secs. 401.055 - 401.115.)

At the local level, the executive officer or governing body of each
county or city is responsible for the emergency services system within
that jurisdiction. Each county must, and each city may, establish an
emergency management agency directly responsible to the executive
officer or governing body of the county or city. The functions of local
emergency management agencies include "coordination of the planning
activities necessary to prepare and maintain a current emergency
operations plan, management and maintenance of emergency operating
facilities from which elected and appointed officials can direct
emergency and disaster response activities, and establishment of an
incident command structure for management of a coordinated response by
all local emergency service agencies." (O.R.S. Sec. 401.305.)

Each county, city, or other municipal corporation may, by ordinance or
resolution, set up its own policy and procedure for the declaration of a
local state of emergency, including what officials are authorized to
make such declarations and under what conditions. The state law
authorizes local officials to order a mandatory evacuation after
declaring a local state of emergency. (O.R.S. Sec. 401.309.)

**Utah**

Emergency management is addressed in Utah Code (U.C.), Title 63,
Chapters 5 and 5a. The statute establishes a Division of Comprehensive
Emergency Management within the Department of Public Safety and charges
it with the responsibility to "prepare, implement and maintain programs
and plans" for disaster prevention and response, including assistance to
local officials in designing local plans, and coordination of emergency
operations plans with the federal government.

The Utah Code also creates a Disaster Emergency Advisory Council,
consisting of state officials and the heads of numerous state agencies,
"to provide advice to the governor on matters relating to state
government emergency disaster response and recovery actions and
activities." (U.C. Sec. 63-5-4.)

During a declared state of emergency the governor is authorized to
utilize all available resources of state government as reasonably
necessary to cope with the emergency, to "recommend and advise the
evacuation of all or part of the population from any stricken or
threatened area," "control ingress and egress to and from a disaster
area, the movement of persons within the area, and recommend the
occupancy or evacuation of premises in a disaster area," and to exercise
other emergency powers. (U.C. Sec. 63-5a-3.)

A "local emergency" may be declared by proclamation of the principal
executive

officer of a political subdivision. Declaration of a local emergency is
"official recognition that a disaster situation exists within the
affected political subdivision and provides a legal basis for requesting
and obtaining state or federal government disaster assistance. The
declaration

activates the response and recovery aspects of any and all applicable
local disaster emergency plans and authorizes the furnishing of aid and
assistance pursuant thereto." (U.C. Sec. 63-5a-6.)

**Washington**

Emergency management in Washington is addressed in the Revised Code of
Washington, (R.C.W.) Title 38, Chapter 38.52. Section 38.52.005 places
responsibility for state emergency management within the state military
department. The emergency management director is charged with carrying
out the state emergency management program, subject to the direction and
control of the governor. The director's duties include, among other
things, developing and maintaining an all‑hazard state emergency plan;
managing related training and public information programs; serving as
liaison with political subdivisions, other states, and the federal
government; managing response operations; and appointing a state
coordinator for radioactive and hazardous waste emergency response
programs (R.C.W. Sec. 38.52.030). The statute also provides for the
Emergency Management Council, a panel of experts whose duties include
advising the governor and director on matters pertaining to emergency
management and arbitrating disagreements between local and state agency
staff on emergency planning.

The governor is assigned general responsibility for control and
implementation of emergency management functions. In a disaster beyond
local control, the governor may assume direct operational control of all
or part of any emergency management functions within the state (Section
38.52.050). In carrying out emergency response functions, the governor
and executive heads of political subdivisions are to use the resources
of state and local government to the extent practicable but are also
authorized to "command the service and equipment of as many citizens as
considered necessary" in light of this disaster, but only after the
governor has issued a proclamation of disaster (Section 38.52.110). The
governor' s power to declare a state of emergency is described in a
separate section of the Code (R.C.W. Sec. 43.06.010) and after such a
declaration, the governor may exercise emergency powers as enumerated in
the law (R.C.W. Sec. 43.06.220).

Local governments are authorized and directed to establish local
emergency management organizations. In an emergency, they are authorized
to bypass normal governmental procedures for procurement, hiring, and
the like in order to carry out emergency response functions. (R.C.W.
Sec. 38.52.070).

\[blank page\]

# ANNEX M: RECOVERY PLANNING IN AN INCIDENT 

# COMMAND SYSTEM CONTEXT

Many communities use the Incident Command System (ICS) to organize their
emergency response organization and operations. An ICS-based
organizational structure may be in place as the focus of activity turns
to recovery. If so, the transition to a recovery-focused effort may
continue that structure, or may involve a reorganization of response
forces. This annex briefly addresses the relationship between an
ICS-based response organization and the recovery organization and
functions described in the workbook model plan.

*Organizational Relationship*

The Incident Command System includes a five-part top-level organization,
with a Command section overseeing a Planning section, Operations
section, Logistics section, and Financial/Administrative section.

The model recovery plan in the workbook makes some very general
assumptions about the organizational structure that will direct and
implement recovery operations. As described in the model plan section
2.2.6, the recovery organization is assumed to include the following
groups: Executive Group, Operations Group, and Technical Group.

Organizationally, the Executive Group as described in the model plan
would likely correspond fairly closely to the Command section found in
the ICS. The Operations Group would be a coordinating group for the
Operations section under the ICS. The Technical Group, in handling
functions relating to gathering and analyzing hazard information, might
correspond best to the ICS Planning section or the Operations section
depending on details of the specific ICS organization.

*Functional Relationship*

The main part of the model plan is devoted to planning for specific
functions that are anticipated to be important during recovery from a
chemical event:

Hazard Assessment

Access to Restricted Areas

Ingestion Pathway Protection

Medical Services

Relocation

Social Services

Public Information

Claims and Disaster Assistance

Environmental Remediation

In general, these functions are of the sort that would fall under
"Operations" in the ICS organizational scheme. Each function might be
the subject of a function-oriented branch, division, group, or strike
team. Therefore the bulk of the model recovery plan would speak to the
work of the Operations section in an ICS-based organization. The
Planning section would develop plans, policies and strategies for
carrying these functions out, and the Logistics and
Administrative/Finance sections would support the Operations section in
carrying out these functions.

In some cases, particular functions in the model recovery plan might
fall primarily under ICS Planning or Command sections rather than
Operations. In particular, the Hazard Assessment function involves
collection and analysis of technical information, and processing it to
support protective action decisions; in some ICS organizations those
functions might be handled primarily under the Planning section rather
than Operations, and the actual decision making would be a function of
the Command section. Also, the Public Information function would likely
be handled directly out of the Command section in an ICS organization.

# ANNEX N: ACRONYMS

ANL Argonne National Laboratory

AR Army regulation

ARAR applicable or relevant and appropriate requirement

ARC American Red Cross

ATSDR Agency for Toxic Substances and Disease Registry (of HHS)

BDO Battledress Overgarment

CAI chemical accident or incident

CAIRA chemical accident or incident response and assistance

CDC Centers for Disease Control

CERCLA Comprehensive Environmental Response, Compensation, and Liability

Act (Superfund)

CFR Code of Federal Regulations

CSDP Chemical Stockpile Disposal Program

CSEP Chemical Stockpile Emergency Preparedness

CWA Chemical Warfare Agent

D2PC An Army computer dispersion model for hazard estimation

D2-Puff^TM^ Updated Army computer dispersion model for hazard estimation

DA U.S. Department of the Army

DAC Disaster Assistance Center

DA Pam U.S. Department of the Army Pamphlet

DERP Defense Environmental Restoration Program

DHHS U.S. Department of Health and Human Services

DMA Disaster Mitigation Act of 2000

DOC U.S. Department of Commerce

DOD U.S. Department of Defense

DODI U.S. Department of Defense Instruction

DOE U.S. Department of Energy

DOI U.S. Department of the Interior

DSMOA Defense-State Memorandum of Agreement

EAS emergency alert system

EIS environmental impact statement

EMI Emergency Management Institute

EMS Emergency Medical Services

EMT Emergency Medical Team

EOC Emergency Operations Center

EPA U.S. Environmental Protection Agency

EPCRA Emergency Planning and Community Right-to-Know Act

EPZ emergency planning zone

**Annex N: Acronyms cont'd**

FDA U.S. Food and Drug Administration

FEMA Federal Emergency Management Agency

FM field manual

FR Federal Register

FRP Federal Response Plan

FTCA Federal Tort Claims Act

GA Tabun (nerve agent)

GB Sarin (nerve agent)

GD Soman (nerve agent)

GPL general population limit

H sulfur mustard (blister agent)

HD distilled sulfur mustard (blister agent)

HBESL health-based environmental screening level

HMGP Hazard Mitigation Grant Program

HT mustard-T mixture (a blister agent)

IC installation commander

ICS incident command system

IDLH immediately dangerous to life and health

IPT integrated process team

IRP Installation Restoration Program

IRZ immediate response zone

JIC Joint Information Center

JIS Joint Information System

L Lewisite (blister agent)

MCA Military Claims Act

MCE maximum credible event

MOA Memorandum of Agreement

MOU Memorandum of Understanding

NCP National Contingency Plan

NEPA National Environmental Policy Act

NIOSH National Institute of Occupational Safety and Health

NRC National Response Center

NRT National Response Team

NVOAD National Voluntary Organizations Active in Disaster

**Annex N: Acronyms cont'd**

ODASA Office of the Deputy Assistant Secretary of the Army

ORNL Oak Ridge National Laboratory

OSC on-scene coordinator

OSC/RPM on-scene coordinator/remedial project manager

OSHA U.S. Occupational Safety and Health Administration

OTSG Office of the Surgeon General (Army)

PAPR powered air-purifying respirator

PAR protective action recommendation

PCA Personnel Claims Act

PIO public information officer

PL Public Law

PMCD program manager chemical demilitarization

POC point of contact

PPE personal protective equipment

PRG preliminary remediation goal

QA/QC quality assurance / quality control

RBC risk-based concentration

RCRA Resource Conservation and Recovery Act

RDTE research, development, testing and evaluation

RfD Reference Dose

RI/FS remedial investigation and feasibility study

ROD Record of Decision

RPM remedial project manager

RTAP real-time analytical platform

SBCCOM U.S. Army Soldier and Biological Chemical Command

SCBA self-contained breathing apparatus

SRF service response force

SRFC service response force commander

SRFX service response force exercise

SSL soil screening level

STEL short-term excursion level

TEU Technical Escort Unit

**Annex N: Acronyms cont'd**

ug micrograms

USACE U.S. Army Corps of Engineers

USACHPPM U.S. Army Center for Health Promotion and Preventive Medicine

USARCS U.S. Army Claims Service

USC U.S. Code

USDA U.S. Department of Agriculture

US EPA U.S. Environmental Protection Agency

VX (nerve agent)

WPL Worker Population Limit

# ANNEX O: BIBLIOGRAPHY

[CSEPP Recovery Planning]{.underline}

Anniston Chemical Stockpile Emergency Preparedness Program (CSEPP)
Reentry and Restoration Planning Guide, November 2000, available through
the CSEPP Portal (<http://www.csepp-planners.net/index.asp>).

CSEPP, *Planning Guidance for the CSEPP*, May 17, 1996, especially
Appendix H, "Planning Guidelines for Emergency Support Operations," and
Appendix M, "Planning Guidelines for Recovery-Phase Activities."
Available at <http://www.csepp.army.mil/biblio/>.

Herzenberg, C.L., et al., *Recovery, Reentry, and Restoration from a
Chemical Weapons Accident or Incident: A Concept Paper on Planning*,
Argonne National Laboratory, ANL/DIS TM-14 (April 1994). Available at
<http://www.csepp.army.mil/biblio/>.

[Technical Guides and References]{.underline}

ANL, *CSEPP Memorandum of Agreement and Memorandum of Understanding
(MOA/MOU) Guide*, May 1999. Available at
<http://csepp.army.mil/biblio/>.

CDC, *Final Recommendations for Protecting the Health and Safety against
Potential Adverse Effects of Long-Term Exposure to Low Doses of Agents:
GA, GB, VX, Mustard Agent (H, HD,T), and Lewisite (L)*, Federal
Register, Vol. 53, No. 50, pp. 8504-8507 (Mar. 15, 1988).

CDC, *Proposed Airborne Exposure Limits for Chemical Warfare Agents GA
(Tabun), GB (Sarin) and VX*, Federal Register, Volume 67, No. 5, pp.
894-901 (January 8, 2002). Available at
<http://www.access.gpo.gov/su_docs/aces/aces140.html>.

*CSEPP Off-Post Monitoring Integrated Process Team Report*, January
1999. Available at <http://csepp.army.mil/biblio/>.

CSEPP Policy Paper #2, *Environmental Sampling to Determine Agent
Contamination*, 20 September 1993. Available at
<http://csepp.army.mil/biblio/>.

Foust, Cheri B., *Compilation of Existing Chemical Agent Guidelines*,
ORNL/TM-13649 (1997). Available at
<http://CSEPPweb-emc.ornl.gov/CSEPPPublications.html>.

Foust, Cheri B., *How Do I Know? A Guide to the Selection of Personal
Protective Equipment for Use in Responding to a Release of Chemical
Warfare Agents*, ORNL/TM-13343 (May 1999). Available at
<http://CSEPPweb-emc.ornl.gov/CSEPPPublications.html>.

OSHA, *Hazardous Waste Operations and Emergency Response*, 29 CFR
1910.120 (worker safety regulations). Available at
<http://www.access.gpo.gov/nara/cfr/cfr-table-search.html>.

USACHPPM, *Derivation of Health-based Environmental Screening Levels For
Chemical Warfare Agents: A Technical Evaluation* (March 1999) Aberdeen
Proving Ground, Maryland, available at
<http://chppm-www.apgea.army.mil/hrarcp/CAW/doc.html>.

Watson, A.P., and N.B. Munro, *Reentry Planning: The Technical Basis for
Off-Site Recovery Following Warfare Agent Contamination*, Oak Ridge
National Laboratory Report ORNL-6628, Oak Ridge, Tenn. (Apr. 1990).
Available at

<http://CSEPPweb-emc.ornl.gov/CSEPPPublications.html>.

Watson, A.P., et al., *Estimated General Population Control Limits for
Unitary Agents in Drinking Water, Milk, Soil, and Unprocessed Food
Items*, Oak Ridge National Laboratory Report, ORNL/TM-12035, Oak Ridge,
Tenn. (Jan. 1991). Available at

<http://CSEPPweb-emc.ornl.gov/CSEPPPublications.html>.

Watson, A.P., F.R. Sidell, S.F. Leffingwell, and N.B. Munro, *General
Guidelines for Medically Screening Mixed Population Groups Potentially
Exposed to Nerve or Vesicant Agent*, Oak Ridge National Laboratory
Report, ORNL/TM-1230L, Oak Ridge, Tenn. (Jan. 1992). Available at
<http://CSEPPweb-emc.ornl.gov/CSEPPPublications.html>.

Yantosik et al., *Temporary Shelter-In-Place as Protection Against a
Release of Airborne Hazardous Material: Report of a Literature Search*,
(16 March 2001). Available through the CSEPP Portal
(<http://www.csepp-planners.net/index.asp>).

Yantosik et al., *When and How to End Shelter-In-Place Protection From a
Release of Airborne Hazardous Material: Report on a Decision-Making
Concept and Methodology*, (30 July 2001). Available through the CSEPP
Portal (<http://www.csepp-planners.net/index.asp>).

[Glossary of CSEPP Terms]{.underline}

Kingan, Robert J., *Chemical Stockpile Emergency Preparedness Program
(CSEPP) Glossary*, Second Edition (updated February 1996). Available
through the CSEPP Portal (<http://www.csepp-planners.net/index.asp>).

[Incident Command System]{.underline}

Firefighting Resources of California Organized for Potential Emergencies
(FIRESCOPE), *Field Operations Guide*, ICS 420-1, available from
[http://firescope.oes.ca.gov](http://firescope.oes.ca.gov/).

FEMA Emergency Management Institute, *Basic Incident Command System
Independent Study Course*, IS-195, available at
<http://training.fema.gov/EMIWeb/crslist.htm>.

National Association for Search and Rescue (NASAR), *Incident Commander
for Search and Rescue -- Student Handbook* (course materials). For
information on this course, see the NASAR website, section on education,
<http://www.nasar.org/training/courses.shtml>.

[Army Regulations and Pamphlets]{.underline}

(Note: Army regulations and pamphlets are available at
[http://www.usapa.army.mil](http://www.usapa.army.mil/).)

AR 27-20, *Claims*, 31 December 1997.

AR 50-6, *Chemical Surety*, 1 February 1995.

AR 200-1, *Environmental Protection and Enhancement*, 21 February 1997.

DA Pam 50-6, *Chemical Accident or Incident Response (CAIRA)
Operations*, 17 May 1991.

DA Pam 27-162, *Claims Procedures*, 1 April 1998.

[^1]: See Yantosik et al., *Temporary Shelter-In-Place as Protection
    Against a Release of Airborne Hazardous Material: Report of a
    Literature Search*, (16 March 2001) p. 46, paragraph 5.4.1.

[^2]: ^2^ (*The term " projected hazard area" is used to denote the area
    that may be affected by an agent plume, according to computer
    modeling. It can be a "wedge" if D2PC is used for plume modeling, or
    a "risk envelope" if D2-Puff^TM^ is used.*)

[^3]: Note: Unrestricted reentry might have to be delayed if cleanup and
    recovery operations on-post will pose a risk of agent release. For
    example, if damaged munitions have to be moved, that may pose a risk
    of agent release and require that reentry be postponed until the
    operation is completed.