Emergency Response Plan

SECTION 1Purpose, Scope and Relationship to Other Plans

29 CFR 1910.120(q)(1)

1.1 Purpose

This is the emergency response plan for Perry's Awesomeness Factory, Building B, required by 29 CFR 1910.120(q)(1). It sets out how the Building B Emergency Response Team (ERT) responds to releases, or substantial threats of releases, of hazardous substances on the Perry Industries campus at 1 Perry Parkway, New Mos Eisley. The plan is in place before any emergency response operation begins.

1.2 Scope

This plan applies to every response by the Building B ERT: in Building B, the flammable tank farm, the ammonia storage area, both tank truck unloading pads, the R-101 room, the Awesomeness and Brilliance lines, packaging, shipping, the 90-day hazardous waste area (HWA), Lab/QC, the transformers and GEN-1; and in Building A and Building C when the control room calls the ERT (Campus Emergency Action Plan, Section 3.5 for Building C).

Releases that employees in the immediate area can absorb, neutralize or otherwise control at the time of release are incidental releases. They are handled under Campus Emergency Action Plan Section 13 and are not emergency response under this plan. Employees who are not ERT members do not take part in emergency response. They report the release, get away from it and keep others out, and evacuate or shelter as the Campus Emergency Action Plan directs.

1.3 Regulatory Basis

Building B employees respond to releases, so Perry Industries keeps this written plan under 29 CFR 1910.120(q) rather than relying on evacuation alone (1910.120(q)(1)). This plan is also the written emergency response plan for the Polyjuice Base process under 40 CFR 68.95 (RMP-PJB-001, Section 7.2), and the LQG Contingency Plan counts the emergency response training given under this plan for ERT members (40 CFR 262.17(a)(7)(i)(D)).

1.4 Relationship to Other Plans

1910.120(q)(2) requires the elements of this plan to the extent they are not addressed elsewhere. The plans below address some of them; this plan refers to them rather than repeating them.

Table 1-1. Related plans.

1.5 Availability of the Plan

This plan is in writing and is available for inspection and copying by employees, their representatives and OSHA personnel (1910.120(q)(1)). Controlled copies are kept at the locations on the Distribution page. An electronic copy is on the plant document system.

SECTION 2Hazardous Substances and Emergency Recognition

1910.120(q)(2)(iii)

2.1 Materials the ERT May Respond To

Exposure limits and transport guide numbers are taken from the safety data sheets in the SDS binders (Building B control room and HWA entrance, Building A lab office, Building C dispatch office) and on the plant document system.

Table 2-1. Hazardous substances on campus.

2.2 How Releases Are Recognized

• Ammonia detectors AD-1 to AD-4 around T-2: alarm at 25 ppm, high alarm at 50 ppm, in the control room.
• LEL detectors LD-1 to LD-3 in the R-101 room: alarm at 10% LEL; high alarm at 25% LEL trips ESD-101.
• Tank alarms: T-2 high-level alarm LAH-201; T-4 interstitial monitor; Building C D-1 and D-2 high-level alarms and interstitial monitors.
• Operator rounds. The weekend and overnight operator records T-1, T-2, T-3 and T-4 levels and the detector readings on each round.
• Attended tank truck deliveries, received on day shift Monday to Friday only.
• Employee reports under Campus Emergency Action Plan Section 3, and Building C reports under Section 3.5.
• What people notice: liquid on the floor or ground, a sharp ammonia odor (ammonia odor threshold, mean 17 ppm), an alcohol odor, a sheen at a storm inlet or at Outfall 001.

2.3 Prevention

Releases are prevented under the PSM program (operating procedures, mechanical integrity, ESD-101 and safe hold of R-101 at the end of each night shift and before weekends), the RMP prevention program for T-2, both SPCC Plans, and LQG Contingency Plan Section 3. The ERT inspects its equipment monthly and after each use (Section 10.4) so it is ready when a release occurs.

SECTION 3Roles, Lines of Authority and Communication

1910.120(q)(2)(ii), (q)(3)

3.1 Lines of Authority

1. The Emergency Coordinator (EC) on duty is the individual in charge of the site-specific Incident Command System (ICS) from the time the ERT is called until NMEFD arrives (1910.120(q)(3)(i)). The EC order is: Steve Resko (primary, days); Marty McFly (nights, 2:30 to 11:00 p.m.; first call after 11:00 p.m. and on weekends); Jenn Resko; Montgomery Scott. The same people are the Emergency Coordinators under the Campus Emergency Action Plan and the LQG Contingency Plan.
2. Until the EC reaches the scene, the ERT Leader on shift (Steve Resko on days, Marty McFly on nights), or the senior ERT member on scene, is in charge.
3. When NMEFD arrives, the senior NMEFD officer becomes the individual in charge, and command passes up NMEFD's line of authority. The Perry EC stays at the command post as the senior official present for Perry Industries and directs Perry employees through the NMEFD incident commander.
4. All responders and their communications are coordinated and controlled through the individual in charge. No one enters a release area unless the individual in charge has assigned them to.

The command post is at AA-2 "Shire" (Gate 2 visitor lot) unless it is downwind of the release, in which case it moves to AA-1 "Rivendell" (Gate 1 lot). Gate 2 security directs NMEFD to the command post.

3.2 Response Roles

The individual in charge assigns these roles on the scene. They are roles, not job titles. One person may hold more than one role when few responders are available, but the safety official is never the individual in charge, and entry team members hold no other role while they are in the hot zone.

Table 3-1. Response roles.

3.3 Who Is Available, by Shift

Table 3-2. ERT and EC coverage. The full shift rosters are in Campus Emergency Action Plan Appendix E.

Building C is open from 5:00 a.m. to 3:30 p.m., Monday to Saturday. From 5:00 to 6:00 a.m. on weekdays and all day Saturday, no ERT member is on shift, and the on-call EC calls back the ERT (Campus Emergency Action Plan Section 3.5).

3.4 Communication

• Plant radio Channel 1 is the emergency channel. During a response it carries response traffic only. Two spare Channel 1 radios are kept in the ERT room.
• Building B control room: ext. 0, outside line (555) 555-0110. Gate 2 security: ext. 2, outside line (555) 555-0112, 24 hours.
• Each entry team has a radio and stays in contact with the entry team leader. Hand signals for the entry are agreed at the pre-entry briefing. If radio contact is lost, the entry team leaves the hot zone by the planned route.
• Orders and readings are repeated back by the person receiving them.
• Emergency withdrawal: the individual in charge or the safety official calls "Emergency, all teams out" on Channel 1, three times. Every entry team leaves the hot zone at once through decontamination.

Table 3-3. Contacts.

SECTION 4Pre-Emergency Planning and Coordination with Outside Parties

1910.120(q)(2)(i), (q)(2)(xii)

4.1 Outside Parties

Table 4-1. Outside parties.

4.2 Community Emergency Response Plan

This plan is coordinated with the New Mos Eisley community emergency response plan prepared under EPCRA section 303. Perry Industries gives the LEPC and NMEFD this plan, the Campus Emergency Action Plan and updated contacts, and gives other information on request. NMEFD runs the community notification system (reverse-call and sirens) for the neighborhood north of Perry Parkway; the EC asks NMEFD to activate it for any release that reaches, or may reach, the fenceline (RMP-PJB-001, Section 7.2).

4.3 Information Kept at the Command Post

• This plan, the Campus Emergency Action Plan, the LQG Contingency Plan, both SPCC Plans and RMP-PJB-001.
• Drawings PI-C-001 (campus), PI-B-101 (Building B), PI-C-201 (Building C) and PI-A-101 (Building A).
• The SDS for each material in Table 2-1.
• The current Emergency Response Guidebook.
• Shift rosters and the visitor and contractor sign-in sheets (brought by Gate 2 security).

4.4 Drills and Exercises

Table 4-2. Drills and exercises.

SECTION 5Emergency Alerting and Response Procedures

1910.120(q)(2)(ix), (q)(3)

5.1 Calling Out the ERT

1. Whoever discovers a release follows Campus Emergency Action Plan Section 3: move away and upwind, keep others out, call 911 for a fire or injury, and call the control room, ext. 0, or radio Channel 1.
2. The control room operator sounds the employee signal the situation calls for (Campus Emergency Action Plan Section 4.3), pages the ERT Leader and the EC on Channel 1 and by phone, and calls 911 for NMEFD for any fire, injury, release of Polyjuice Base, or release the ERT may not be able to control.
3. The control room operator makes critical operations safe from the console: ESD-101 for the Thunderbolt Solvent System; close XV-201 and stop P-201 for T-2 (Campus Emergency Action Plan Section 7).
4. ERT members on shift report to the ERT room by the control room, dress as the ERT Leader directs and take the equipment. For Building C, the ERT takes the response trailer out door B-6, east to East Drive and south into the truck yard.
5. After 11:00 p.m. and on weekends, the Building B operator on duty or Gate 2 security calls 911, then the on-call EC in the order in Section 3.3. The EC reached calls back the ERT and notifies Dana Scully.

5.2 First Actions on Scene (Size-Up)

1. Approach from upwind and uphill. Check the windsock on the Building B roof.
2. Look for people who are hurt or trapped. Rescue in a release area is made only by ERT members in SCBA and the required PPE, working in pairs with backup ready (Campus Emergency Action Plan Section 9.1).
3. Identify the material from the location, the container or equipment ID, labels and placards, the SDS, the fixed detector readings and the shipping papers on a delivery truck.
4. Set the initial isolation area (Section 6.1) and keep everyone out of it.
5. Report to the individual in charge: material, source, amount released and still leaking, direction of travel, wind, people hurt or missing, and what has been shut down.

5.3 Actions of the Individual in Charge

1. Identify, to the extent possible, all hazardous substances and conditions present, and address site analysis, engineering controls (ESD-101, XV-101, XV-200, XV-201, WM-1 water fog, drain covers), exposure limits, handling procedures and the use of any new technologies (1910.120(q)(3)(ii)).
2. Decide the response: contain from a distance; approach the source to stop the release; or make no entry and wait for NMEFD. The ERT makes no entry when the job needs Level A protection, when fire is beyond the incipient stage, or when a backup team cannot be staffed.
3. Complete the entry plan (Appendix C) before anyone enters: objectives and tasks, hazards and controls for each task, PPE and respiratory protection, entry and backup team names, decontamination, first aid support, entry time limit, communication and the emergency withdrawal signal. Brief the entry and backup teams on it.
4. Limit the people in the hot zone to those actively performing emergency operations. Work in the hot zone is done in pairs or larger groups (1910.120(q)(3)(v)).
5. Name the safety official (1910.120(q)(3)(vii)).
6. Make sure backup personnel stand by with equipment ready, and that first aid support stands by with medical equipment and transportation, before entry (1910.120(q)(3)(vi)).

5.4 Respiratory Protection and Air Monitoring

• Responders exposed to a hazardous substance that presents an inhalation hazard or potential inhalation hazard wear positive-pressure SCBA until the individual in charge determines, through air monitoring, that a decreased level of respiratory protection will not result in hazardous exposures (1910.120(q)(3)(iv)).
• The ERT's entry respirators are SCBA (8 units, 30-minute cylinders). The ammonia escape respirators in SK-10 are for escape only and are never used for entry.
• Where the exposure cannot be identified or reasonably estimated, the atmosphere is treated as IDLH (29 CFR 1910.134(d)(1)(iii)).
• Monitoring equipment: portable 4-gas meter (O2, LEL, CO, H2S) with PID, a spare 4-gas meter, ammonia colorimetric tubes and pump, and the fixed detectors AD-1 to AD-4 and LD-1 to LD-3 read from the control room.
• Entry teams leave the area if the meter reads 10% LEL or more, the alarm point of the fixed LEL detectors.
• Readings, times and locations are recorded on the entry log (Appendix C).

5.5 Protective Equipment

The individual in charge makes sure the PPE worn is appropriate for the hazards (1910.120(q)(3)(iii)). The safety official checks each entrant's PPE before entry. PPE levels and the written PPE program are in Section 10.

5.6 Authority of the Safety Official

When the safety official judges an activity to be an IDLH condition or an imminent danger, the safety official alters, suspends or terminates it and tells the individual in charge at once (1910.120(q)(3)(viii)). Every responder also stops work and reports any condition they believe is unsafe.

5.7 Response Guides by Material

Table 5-1. Response guides.

5.8 Notifications

Dana Scully, EHS Manager, makes the notifications to outside agencies; when she is not on site, the EC on duty makes them (Campus Emergency Action Plan Section 3.6). The release-specific lists are in RMP-PJB-001 Section 7.2 (Polyjuice Base and ammonia vapor), LQG Contingency Plan Section 6.4 (hazardous waste), the Building B SPCC Plan and the Building C SPCC Plan (oil). Reportable quantities are in Sections 6 and 15 of each SDS.

5.9 Ending the Response

1. The individual in charge confirms that the release is controlled and that no further emergency operations are needed.
2. The individual in charge implements decontamination of people and equipment (1910.120(q)(3)(ix); Section 11).
3. The EC directs the control room to sound the all-clear when air monitoring shows it is safe and, if NMEFD is on scene, after consulting NMEFD.
4. Cleanup is handed over under Section 15. The debrief and critique follow Section 14.

SECTION 6Safe Distances and Places of Refuge

1910.120(q)(2)(iv)

6.1 Initial Isolation Area

The ERT sets the initial isolation area from the guide in the current Emergency Response Guidebook for the material (Table 2-1), measured from the release, and adjusts it using the windsock and air monitoring. The individual in charge may enlarge it at any time.

6.2 Places of Refuge

• Assembly areas: AA-1 "Rivendell" (Gate 1 lot), AA-2 "Shire" (Gate 2 visitor lot) and AA-3 "Hoth" (Gate 3 lot), with the alternates in Campus Emergency Action Plan Section 5.7.
• Shelter rooms for an outdoor ammonia release: Building A conference room "The Restaurant at the End of the Universe"; Building B break room and locker rooms; Building C dispatch office and break room (Campus Emergency Action Plan Section 6.3). The control room operator stays in the control room.
• The neighborhood north of Perry Parkway is about 400 ft from the flammable tank farm and about 600 ft from the ammonia storage area. NMEFD and police decide on protective actions for the neighborhood; the EC gives them the release information they need.
• Responders stage in the cold zone, upwind of the release.

SECTION 7Site Security and Control

1910.120(q)(2)(v)

• Hot zone: the area where the release and its hazards are. Only the entry and backup teams on the entry plan go in.
• Warm zone: the decontamination line between the hot zone and the cold zone. Everyone and everything leaving the hot zone goes through it.
• Cold zone: the command post, staging, first aid support and the specialist employees.
• The zones are marked with tape or cones. An ERT member at the entry point keeps the entry log (Appendix C): name, time in, SCBA cylinder pressure, time out.
• Gate 2 security stops inbound traffic. Honey Badger dispatch closes Gate 3 during shelter in place. NMEFD and police control Perry Parkway.
• Tank truck deliveries stop. Visitors and contractors are accounted for under Campus Emergency Action Plan Section 8.
• No one re-enters an evacuated building or the isolation area until the all-clear.

SECTION 8Evacuation Routes and Procedures

1910.120(q)(2)(vi)

• Employee evacuation routes, maps (Figures 1–4), shelter in place and accounting for employees are in Campus Emergency Action Plan Sections 5, 6 and 8.
• ERT routes: from the ERT room by the control room, out door B-6 (ERT only) to the flammable tank farm and the ammonia storage area; for Building C, east on East Drive and south into the truck yard (about 400 ft from door B-6 to Dock 3).
• Emergency withdrawal from the hot zone: on the signal in Section 3.4, entry teams leave by the route on the entry plan and go through decontamination. An injured entrant gets emergency decontamination (Section 11.1). The entry point keeper accounts for every entrant and reports to the individual in charge.

SECTION 9Training

1910.120(q)(2)(ii), (q)(4)–(q)(8)

9.1 Who Responds, and the Training for Each

Training is based on the duties and function of each responder (1910.120(q)(6)).

Table 9-1. Responders and training.

Employees not listed as responders do not take part in emergency response. They report a release, get away from it and keep others out. Campus Emergency Action Plan Appendix E shows each person's HAZWOPER technician status.

9.2 Training Before Taking Part

A new ERT member, EC or specialist employee takes part in actual emergency operations only after completing the training for that role (1910.120(q)(6)). Until then they do not enter the hot zone or hold a role in Table 3-1.

9.3 Hazardous Materials Technician

Each ERT member has at least 24 hours of training equal to the first responder operations level, and competency in the following areas, and Perry Industries so certifies (1910.120(q)(6)(iii)):

1. Know how to implement the employer's emergency response plan.
2. Know the classification, identification and verification of known and unknown materials by using field survey instruments and equipment.
3. Be able to function within an assigned role in the Incident Command System.
4. Know how to select and use proper specialized chemical personal protective equipment provided to the hazardous materials technician.
5. Understand hazard and risk assessment techniques.
6. Be able to perform advance control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available with the unit.
7. Understand and implement decontamination procedures.
8. Understand termination procedures.
9. Understand basic chemical and toxicological terminology and behavior.

Site-specific training covers: this plan; the materials in Table 2-1 and their SDSs; SCBA donning, use and cylinder changes; the Level B suits; the 4-gas meter with PID and the ammonia tubes; ESD-101, XV-101, XV-200 and XV-201; WM-1; drain covers, booms and overpacks; the decontamination line; and the layout of Buildings A, B and C on the drawings.

9.4 On-Scene Incident Commander

Each Emergency Coordinator has at least 24 hours of training equal to the first responder operations level, and competency in the following areas, and Perry Industries so certifies (1910.120(q)(6)(v)):

1. Know and be able to implement the employer's incident command system.
2. Know how to implement the employer's emergency response plan.
3. Know and understand the hazards and risks associated with employees working in chemical protective clothing.
4. Know how to implement the local emergency response plan.
5. Know of the state emergency response plan and of the Federal Regional Response Team.
6. Know and understand the importance of decontamination procedures.

Steve Resko, Marty McFly and Montgomery Scott hold both the technician and the incident commander certifications. Jenn Resko holds the incident commander certification only and does not enter the hot zone.

9.5 Specialist Employees

Specialist employees work with and are trained in the hazards of specific hazardous substances in their regular jobs and give technical advice to the individual in charge. They receive training or demonstrate competency in their area of specialization annually (1910.120(q)(5)).

Table 9-3. Specialist employees.

9.6 Skilled Support Personnel

Perry Industries does not designate its own employees as skilled support personnel. When an outside operator of equipment such as earth-moving, digging, crane or hoisting equipment is needed temporarily and may be exposed to the hazards at the scene, the individual in charge or the safety official gives that person an initial briefing at the site before they take part: how to wear the PPE provided, the chemical hazards involved, and the duties to be performed. They get the same safety and health precautions as Perry responders (1910.120(q)(4)). The briefing is recorded on the response log.

9.7 Annual Refresher

Every ERT member, Emergency Coordinator and specialist employee receives annual refresher training of sufficient content and duration to maintain their competencies, or demonstrates competency in those areas at least yearly (1910.120(q)(8)(i)). The refresher includes hands-on work with the ERT equipment and a review of the responses, drills and exercises of the past year. A statement of the training or competency is made for each person; where competency is demonstrated, the method used is recorded (1910.120(q)(8)(ii)).

9.8 Respirator Training, Medical Evaluation and Fit Testing

• Each SCBA user receives respirator training that recurs annually, and more often if necessary (29 CFR 1910.134(k)).
• Each SCBA user has a medical evaluation before fit testing or first use (1910.134(e); Section 13).
• Each SCBA user is fit tested before first use, whenever a different facepiece is used, and at least annually (1910.134(f)(2)). Kaitlyn Perry, RN, does the fit testing.

9.9 Trainers

The 24-hour technician course, the incident commander course and the annual refresher are given by an outside training provider whose instructors have the training, credentials and instructional experience required by 1910.120(q)(7). Site-specific and hands-on sessions are given by Steve Resko, ERT Leader; meter training is given by Montgomery Scott, who calibrates the meters.

9.10 Certification and Records

Hari Seldon, Plant Manager, signs the technician and incident commander certifications (Appendix B) on the ERT Leader's recommendation. Human Resources (Wendy Weaver) keeps, for each person: name, course or session, date, hours, trainer, and the means used to verify competency, with the signed certification and the annual refresher statement.

Table 9-2. Training matrix.

SECTION 10Personal Protective Equipment and Emergency Equipment

1910.120(q)(2)(xi), (q)(10), (g)(3)–(g)(5)

10.1 ERT Equipment

Table 10-1. Emergency equipment.

10.2 Levels of Protection

Table 10-2. Levels of protection.

Glove and suit material for each entry is chosen from Section 8 of the SDS and the manufacturer's chemical resistance data.

10.3 Written PPE Program

The chemical protective clothing and equipment used by the ERT meets 1910.120(g)(3) through (g)(5) (1910.120(q)(10)). The PPE program elements are:

Table 10-3. PPE program.

10.4 Inspection and Maintenance

• The ERT inspects all ERT equipment monthly and after each use (Appendix D).
• SCBA are serviced as the manufacturer requires. Cylinders are refilled at the cascade at the Gate 2 house after each use. A spare cylinder is used only on an SCBA of the same capacity and pressure rating (1910.120(q)(3)(x)).
• The portable meters are calibrated monthly by Montgomery Scott and bump-tested before each use.
• Ammonia detectors AD-1 to AD-4 are bump-tested monthly and calibrated quarterly.
• Spill kits are inspected monthly and restocked after use (LQG Contingency Plan Section 3.3).
• Defective equipment is tagged out and replaced before the ERT is considered ready.

SECTION 11Decontamination

1910.120(q)(2)(vii), (q)(3)(ix)

11.1 Emergency Decontamination

A person who is contaminated and hurt, or splashed with a corrosive, is decontaminated at once: remove contaminated clothing and flush with water for at least 15 minutes at the nearest safety shower or eyewash outside the hazard (SS-1 flammable tank farm, SS-2 flammable/oil unloading pad, SS-3 Awesomeness line, SS-4 ammonia storage area) or with the decontamination hose. People come first; runoff is contained afterward.

11.2 Decontamination Line

1. The decontamination line is set up in the warm zone, upwind of the hot zone, before anyone enters.
2. Equipment drop: tools and equipment are left at the hot zone edge on plastic.
3. Gross wash: the entrant stands in the decontamination pool and is washed down with water and brushes, top to bottom. Soap and water are used for oils and Thunderbolt; plain water for corrosives and Polyjuice Base. Neutralizers are never used on people.
4. Rinse.
5. Outer gloves and boots, then the suit, are removed with help from the decontamination team.
6. The SCBA facepiece is removed last.
7. The entrant goes to the safety official and first aid support for a check.

11.3 Wash Water and Equipment

Wash water stays in the decontamination pool and is collected, tested and managed under the LQG Contingency Plan; caustic wash water at pH 12.5 or higher is D002 hazardous waste. Nothing leaves the hot zone without decontamination. Reusable equipment is cleaned and inspected before it goes back into service; disposable items are bagged.

SECTION 12Emergency Medical Treatment and First Aid

1910.120(q)(2)(viii), (q)(3)(vi)

• Before any entry into the hot zone, the individual in charge requests an EMS unit through 911 to stand by at the command post, unless NMEFD EMS is already on scene. A first aid responder with the trauma bag and AED from the Building B nurse's station also stands by in the cold zone (1910.120(q)(3)(vi)).
• Kaitlyn Perry, RN, Occupational Health Nurse, gives first aid and triage until EMS arrives. First aid, CPR and AED responders are listed in Campus Emergency Action Plan Appendix C.
• Chemical contact: flush at once (Section 11.1). Ammonia inhalation: move to fresh air; oxygen is given only by trained personnel.
• Injured or exposed people go to Tiberius Regional Medical Center. The SDS, or the trade name if the SDS is not at hand, goes with the person. Gate 2 security meets the ambulance.
• Any responder who shows signs or symptoms that may have resulted from exposure during the response, then or later, is provided medical consultation (Section 13.3).

SECTION 13Medical Surveillance

1910.120(q)(9), (f); 1910.134(e)

13.1 Who Is Covered

The Building B ERT is an organized and designated hazmat team. All 12 ERT members receive a baseline physical examination and medical surveillance (1910.120(q)(9)(i), (f)(2)(iv)).

13.2 Examinations

Table 13-1. Examination schedule.

Examinations are done by Tiberius Regional Medical Center Occupational Health under the supervision of a licensed physician, at no cost to the employee, without loss of pay, at a reasonable time and place (1910.120(f)(5)). Kaitlyn Perry, RN, schedules them and gives the physician a copy of 1910.120 and its appendices and the information in 1910.120(f)(6), including the respirator information required by 1910.134. The physician's written opinion is given to the employee (1910.120(f)(7)). The respirator medical evaluation required by 1910.134(e) is part of the examination.

13.3 Medical Consultation After a Response

Any responder who may have been injured, developed signs or symptoms, or been exposed above the PEL or published exposure level without the necessary PPE during a response is provided a medical consultation as soon as possible after the incident (1910.120(q)(9)(ii), (f)(3)(ii)). This applies to every responder, not only ERT members.

13.4 Records

Medical surveillance records are kept by Kaitlyn Perry, RN, separate from personnel files, for at least the duration of employment plus 30 years (1910.120(f)(8); 1910.1020(d)(1)(i)).

SECTION 14Critique of Response and Follow-Up

1910.120(q)(2)(x)

1. Debrief: when the release is controlled, and at each shift change during a long response, the individual in charge holds a short debrief with the responders: whether anyone is hurt or exposed, what went well, and what anyone would do differently.
2. Written critique: within 14 days the ERT Leader writes a critique of the response: the timeline, what worked, what did not, equipment used and its condition, exposures and injuries, and recommendations.
3. Corrective actions: each recommendation gets an owner and a due date. Dana Scully tracks them to closure.
4. Drills and exercises are critiqued the same way. RMP exercises get an evaluation report within 90 days (40 CFR 68.96(b)(3)).
5. Related reports: incident investigation under the PSM program or RMP-PJB-001 where they apply; the LQG Contingency Plan operating record entry and 15-day written report (262.265(i)) for a hazardous waste emergency.
6. Before the ERT is considered ready again: equipment is decontaminated, inspected, refilled and restocked, and the response is reviewed against this plan (Section 16).

SECTION 15Post-Emergency Response Operations

1910.120(q)(11)

When the emergency response is over and hazardous substances or contaminated materials must be removed from the site, the cleanup is post-emergency response.

• Sheaves Environmental Response, as the employer conducting the cleanup, does the cleanup and removal under 1910.120(q)(11).
• Perry employees who clean up on plant property have completed training under 29 CFR 1910.38, 1910.134 and 1910.1200, and the PPE and decontamination training the task requires. Equipment used is in serviceable condition and inspected before use (1910.120(q)(11)(ii)).
• When ERT members who took part in the initial response continue the cleanup, it is part of the initial response under this plan (1910.120(a)(3)).
• Recovered material and contaminated debris are managed under the LQG Contingency Plan (Section 6.7) and the SPCC Plans for oil.

SECTION 16Plan Review and Update

Steve Resko, ERT Leader, reviews this plan at least once a year and after any of the following, and updates it as needed:

• A response, drill or exercise that shows a need for change.
• A change in processes, chemicals, quantities, equipment or the layout of the campus.
• A change in a person named in this plan, an Emergency Coordinator, or an ERT member.
• A coordination meeting with NMEFD or the LEPC, or a change in the community emergency response plan.
• An incident investigation that shows a need for change.
• A change to the Campus Emergency Action Plan, RMP-PJB-001, the PSM program, the LQG Contingency Plan or either SPCC Plan that affects this plan.

Employees affected by a change are told at shift meetings. Revised copies go to every location on the Distribution page, including NMEFD Station 7 and the New Mos Eisley LEPC.

APPENDIX ARegulatory Cross-Reference

Table A-1. Cross-reference.

APPENDIX BTraining Certification

Perry Industries certifies that the employee named below has received at least 24 hours of training equal to the first responder operations level and has competency in each area listed for the level checked, under 29 CFR 1910.120(q)(6).

Original to Human Resources. Copy to the ERT Leader.

Annual Refresher Statement (1910.120(q)(8))

APPENDIX CEntry Plan and Entry Log

Completed by the individual in charge before any entry into the hot zone. Briefed to the entry and backup teams. Kept with the response log.

Entry Log

APPENDIX DMonthly ERT Equipment Inspection

Month and year: ______________________ Inspected by: ______________________

Signature: ______________________ Date: ______________