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Guide to the Guide
How to use The National Response Team's Integrated Contingency Plan (ICP) Guidance and the Michigan Contingency Plan Requirements Matrix
The National Response Team's ICP Guidance provides:
- An outline of a comprehensive ICP
- A development matrix that shows where federal plan requirements can be included in the ICP
- Regulatory cross-comparison matrices that describe the plan requirements in each regulation and identify where each requirement is addressed in the ICP
Michigan has added:
- A development matrix that shows where state plan requirements can be included in the ICP
- Regulatory cross-comparison matrices that describe the plan requirements in each regulation
- A development matrix template
Look at the Federal Register notice of The National Response Team's Integrated Contingency Plan Guidance. Turn to page 17 for the ICP outline. The ICP contains 3 main sections: an introduction, a core plan, and a series of supporting annexes. The basic premise is that the core plan should contain the essential response guidance and procedures. It should fit into the glove-box of a response vehicle. Details should go into the annexes. Annexes should augment, not duplicate, the core plan information.
Tailor the plan to the specific facility. For example, complex facilities will rely more heavily on references to specific annexes, and some facilities might need to consider the need for bilingual notification.
If your facility is subject to plan requirements under federal and/or state regulations, you will want to refer to the federal and state matrices. The matrices identify the plan elements that are specifically required to be included in a contingency plan and identify where in the ICP you might include these elements. For example, if your facility must prepare a Pollution Incident Prevention Plan (PIPP), the "Michigan Contingency Plan Requirements Matrix" indicates that much of the information required under rule 324.2006(1)(a) would be included in the "General facility identification information" part of the plan. The "Michigan Contingency Plan Requirements: Regulatory Cross-Comparison Matrix" describes the rule and thus the required information. The rule description is sometimes abbreviated or paraphrased, so it is recommended that you also refer to the actual regulation.
Remember that you should not duplicate information in the ICP. If the same rule is referenced in different parts of the plan matrix, consider where the information required by that rule would best fit. In the PIPP example, rule 324.2006(1)(a)(x) says the plan should include a map showing the facility relative to the surrounding area. The Michigan plan matrix lists this rule in Section I - Plan Introduction Elements under part 4.e. "Other identifying information" and again in Section III - Annexes under part 1.a. "Facility maps." The map should be included in only one of these sections in the plan.
On July 17, 2002, EPA published in the federal register major revisions to the Spill Prevention, Control and Countermeasures (SPCC) rules. Prior to this publication, SPCC plans were required to be stand-alone plans. The revised regulation allows the SPCC to be contained in an ICP. If you are revising your SPCC to comply with the new regulations, consider presenting it in the ICP format. The federal ICP Development Matrix has not been revised to include the SPCC, so you will need to refer to the regulations to assure that your ICP contains all of the elements required in the SPCC.
While the Storm Water Pollution Prevention Plan required by Michigan regulation is not yet included in the "Michigan Contingency Plan Requirements Matrix," it may be included in the ICP. Refer to the regulations for the plan requirements.
If your facility is subject to contingency planning requirements not addressed in this web site, consult the agency responsible for implementation to assure that they will accept the ICP format.
Use the ICP Development Matrix template to map out where the plan requirements will be included in your ICP.
If the plan must be submitted to a regulatory agency for review, you should create a regulatory cross-comparison matrix based on the plan requirements in the regulation to which the facility is subject. Indicate where each plan requirement is addressed in the ICP. The regulatory cross-comparison matrices only show the section in the ICP where the plan requirement has been met. The page number should also be included. This format is required by EPA Region 5 for the federal Oil Pollution Prevention plans (SPCC and Facility Response Plan).
Refer to the Michigan Facilities' Guide to SARA Title III, Chapter 5 - Contacts for Help Section if you have questions regarding specific planning requirements.
While contingency plans should always be kept on site, only some need to be submitted to the regulatory agency. Refer to the Submittal Guidance for Contingency Plans before you submit your plan to an agency in Michigan.
The National Response Team's Integrated Contingency Plan Guidance provides a format in which all state and federal planning requirements relating to oil and non-radiological hazardous substances can be satisfied. It is recommended, but not mandatory that this format be used.