2.5. Planning Documents

Below are examples of some key topical planning documents typically developed to support chemical incident consequence management priorities across the operational phases discussed in detail above.

Quality Assurance Project Plan (QAPP) – The QAPP establishes the site-specific data quality objectives of the project.

Health and Safety Plan (HASP) – The HASP establishes the overall site-specific safety requirements, work areas, places of refuge, site control, emergency evacuation routes, emergency decontamination procedures, and emergency medical treatment. It specifies necessary emergency equipment including PPE and ensures proper training, medical surveillance, chemical protective clothing, and post-emergency response operations.¹⁸The HASP also includes a weather plan that establishes actions for pending weather events which could impede response and recovery. The HASP establishes the overall site-specific safety requirements, work areas, and levels of personal protection equipment (PPE).

Ambient Air Monitoring Plan (AAMP) – The AAMP establishes air monitoring and sampling frequency and spatial distribution to ensure the safety of the response workers and adjacent public population. It can also be used to determine the migration of plumes and direct evacuation or shelter-in-place actions. It can also combine real-time air monitoring with air samples that will be submitted for subsequent analysis. The AAMP is typically utilized to support a number of different consequence management activities across operational phases of the response and recovery effort.¹⁹

Sampling and Analysis Plan (SAP) – The SAP establishes the number and spatial distribution of samples in all matrices (air, soil, water, materials) during site remediation. The AAMP may be incorporated into the SAP.

Remedial Action Plan (RAP) – The RAP establishes the decontamination technologies and methods to be used to remediate the site.

Waste Management Plan (WMP) – The WMP identifies necessary decision-making processes and available information for management of the waste generated from the contamination incident and remediation efforts. Representatives from the appropriate treatment, storage, and disposal facilities should be identified early in the initial stages to provide information on waste characterization requirements. States may have more stringent regulations on CWA-generated waste than the Federal government; this will require further input from waste receivers and regulators.²⁰Hazardous waste activities will need to be regulated, and how compliance with appropriate regulations or permits will be accomplished needs to be planned for and a risk communications strategy developed.

Data Management Plan (DMP) – A DMP outlines a comprehensive approach to data management to ensure that data collection produces a consistent data set to enhance understanding and communication of an evolving conceptual site model (CSM). A consistent approach for collecting, processing, and analyzing data facilitates the decision-making team’s data transfer and integration, which allows for more effective sharing among data partners, users, and project stakeholders.

These planning documents are created and used during different phases of response and recovery, and individual documents can be used for multiple purposes and may be updated multiple times as the response and recovery effort evolves. For example, often one SAP will be developed to support characterization activities, and another to support clearance activities. Each of the individual types of plans discussed above will have tailored data collection requirements that will need to be included in an overarching data collection/records management plan. Additionally, each type of plan should include environmental justice considerations based on the outcomes of detailed analysis of potential underserved and underrepresented communities impacted by the incident.

Additional planning guidance documents may be found at the EPA On-Scene Coordinator website. Further, the Worker health and Safety Support Annex to the NRF provides federal guidance to FSLTT response and recovery organizations in assuring worker safety and health during incidents requiring a coordinated Federal response.²¹

Footnotes

18. See https://www.osha.gov/emergency-preparedness/hazardous-waste-operations/preparedness. Also see OSHA 1910.120 in general and this webpage in particular on OSHA HAZWOPER: https://www.osha.gov/emergency-preparedness/hazardous-waste- operations/background. Additionally, the Superfund Amendments Reauthorization Act (SARA) of 1986 required OSHA to issue regulations protecting workers engaged in hazardous waste operations. OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standards (in general industry, 29 CFR 1910.120; and construction 29 CFR 1926.65) established health and safety requirements for employers engaged in these operations, as well as responses to emergencies involving releases of hazardous substances. HAZWOPER requires that employers follow specific work policies, practices, and procedures to protect their workers potentially exposed to hazardous substances. The standards provide employers with the information and training criteria necessary to ensure workplace health and safety during hazardous waste, emergency response, and cleanup operations involving hazardous substances. HAZWOPER aims to prevent and minimize the possibility of worker injury and illness resulting from potential exposures to hazardous substances.

19. Note: Ambient air monitoring is most applicable for volatile or highly volatile chemicals.

20. U.S. Environmental Protection Agency (2018). Best Practices to Minimize Laboratory Resources for Waste Characterization During a Wide-Area Release of Chemical Warfare Agents.

21. This annex describes coordination mechanisms, policies, and processes to provide technical assistance for response/recovery worker safety and health management activities that include anticipation, identification, and mitigation of response/recovery risks and hazards. These mechanisms also include the assessment and analyses of health risks from occupational exposures, to facilitate incident risk management for response and recovery workers. See: Worker Health and Safety Support Annex (fema.gov)