WASHTENAW COUNTY ENVIRONMENTAL RESPONSE PROCEDURE 9/27/12 PURPOSE

WASHTENAW COUNTY ENVIRONMENTAL RESPONSE PROCEDURE 9/27/12 PURPOSE This procedure defines the roles and responsibilities of the Washtenaw County Water Resources Commissioner s Office, Washtenaw County Sheriff s Office Emergency Services Division, and Washtenaw County Public Health Department when an environmental incident or hazardous materials accident occurs in the community. EMPLOYEE TRAINING AND CERTIFICATION Under rule 29 CFR 1910.120 established by the Occupational Safety and Health Administration, it is the employer's responsibility to certify that employees have met standardized training requirements. This section of the procedure will outline the mandatory requirements that must be met before an employee becomes certified by the county to respond to actual or possible hazardous materials accidents. Employees who are not currently certified by the county shall not respond to the scene to manage or assist other local officials with managing any hazardous materials incidents. This does not apply to employees remote from the scene who provide incident managers with consultation or advice. Once the minimum requirements have been met by the employee (as set forth below), the employee shall submit all appropriate documentation to the Emergency Services Director, who will then consult with the county Risk Management Coordinator to verify that the training meets with OSHA guidelines. If the training meets the standard, county certification will then be granted to the employee and the documentation will be forwarded to the Human Resources Department. For awareness and operations level employees, their course completion certificates and continuing education documentation shall serve as county certification. For county approved technician and specialist employees, County Administration will forward a certificate stating the employees name and level of certification to the employee and copies of the certification will be kept by the Human Resources Department. If disapproved, the employee and the employee's department head will be given a letter stating which areas of training did not qualify under OSHA guidelines, or specifying training needs or base line physical requirements that are to be completed prior to county certification. Washtenaw County Employee Certification Levels Hazardous Materials First Responder Awareness - An employee who must know how to identify a chemical emergency, be able to identify specific chemical hazards by interpretation of placards, use of the Department of Transportation Hazardous Materials Guidebook, and take initial self and public protection measures in a defensive fashion is required to have First Responder Awareness level training. The employee must attend 4 hours of hazardous materials training annually. This requirement can be met by attending another awareness course or by participating in any hazardous materials 1

continuing education programs of 4 or more hours and approved by the Environmental Response Managers group. Hazardous Materials First Responder Operations - An employee who must be able to recognize a chemical emergency, identify specific chemical hazards, take initial self and public protection measures in a defensive fashion, and have skills to defensively contain, confine, or mitigate a release must have operations level certification. The employee must first complete the awareness level training, then successfully complete either an EPA approved 40-hour HAZWOPER course or a 24-hour Michigan Fire Fighters Training Council approved First Responder Operations course. Re-certification is automatic provided that the employee annually completes eight or more hours of continuing hazardous materials training. Hazardous Materials Technician - An employee who must have the basic skills of the awareness and operations trained personnel and who may be required to contain, confine, or mitigate a chemical release in an offensive fashion utilizing personal protective equipment must be certified at the technician level. The employee must first successfully complete the Awareness and Operations level training, and then successfully complete the 80-hour Hazardous Materials Technician course at the Michigan Hazardous Materials Training Center. The employee must also pass a base line physical performed by a Washtenaw County approved occupational health physician. To re-certify, the technician employee must complete 16 hours of hazardous materials or emergency response training annually, and submit the training documentation to the Emergency Services Director. Hazardous Materials Specialist - An employee who must possess the knowledge and skills of the technician certified worker and who must also possess knowledge about hazardous materials chemistry, emergency planning implementation, basic toxicology, and risk assessment needed for the management of major hazardous materials accidents must be certified at the specialist level. The employee must have successfully completed the requirements set forth for awareness, operations, and technician level certification and also successfully complete the National Fire Academy approved Chemistry of Hazardous Materials course, the Federal Emergency Management Agency approved Hazardous Materials Contingency Planning course, the Michigan Fire Fighters Training Council Hazardous Materials Incident Command course, and the Michigan Hazardous Materials Training Center Hazardous Materials Specialist course. The employee must also pass a base line physical performed by a Washtenaw County approved occupational health physician identical to the technician level. To re-certify, the specialist employee must complete 24 hours of training annually, and submit the documentation to the Emergency Services Director. Base Line Physical for Technicians and Specialists - The base line physical shall be performed by a board certified occupational health physician. County Risk Management is responsible for selecting the health care organization providing the base line physical, and for retaining the confidential examination reports. The examination performed shall include the following tests: 1. Occupational History and Physical Exam (initially and periodically) 2

2. Respirator Use Evaluation 3. Audiogram 4. Lab Work (blood drawn for the following) *Heavy Metal Screen (Arsenic, Mercury, Lead) *Cadmium (blood - ARUP lab) *Comprehensive Panel w/complete urinalysis including CBC, Platelet count, GOT, Albumin, Alkaline Phosphatase, Calcium, Cholesterol, LDH, Creatinine, Glucose, Phosphorus, Potassium, Protein, and Urea Nitrogen 5. Chest X-Ray, 2 view AP & Lateral w/oblique; at physician's discretion only. 6. Electrocardiogram; at physician's discretion only, based on exposure potential. DEPARTMENT ROLES AND RESPONSIBILITIES Sheriff Emergency Services Division All reports of incidents involving any accidental or intentional spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing of any hazardous, or potentially hazardous unknown substances into the environment shall be screened by the county s Hazardous Materials Emergency Coordinator (Emergency Services Director) or Assistant Hazardous Materials Emergency Coordinator (an Emergency Services Division Coordinator). Callers who report these incidents to county departments other than Washtenaw Metro Dispatch or the Emergency Services Division directly should be immediately referred to 9-1-1. Reports of non-hazardous, non-emergent environmental accidents such as non-leaking abandoned drums should be referred to the Emergency Coordinator or designee for further screening. In the case of a 9-1-1 center HAZMAT referral or a direct call from witness, the Emergency Coordinator or designee will determine the initial level of response from Washtenaw County departments based on the response guidelines established below. In any event where the public safety is at risk from a spill or leak, the Emergency Coordinator or designee will assure that the Fire Department with jurisdiction is responding. If it is evident that a specific response is necessary and that the situation is clearly non-emergent, then the Emergency Coordinator or designee will make or direct staff to make all appropriate notifications to county departments or the Department of Environmental Quality in a timely fashion. If it is determined by the Emergency Coordinator or designee that a response to the scene is necessary, immediately upon arrival a population and environmental threat assessment will be performed in conjunction with the Incident Commander. Any products or substances released will be identified, if possible, and documented. In the event that the public is or may be at substantial risk from the spill or release, the Emergency Coordinator or designee may do one or more of the following: 3

Determine if other county or state departments are required on the scene. Activate the Emergency Alert System to inform other public safety and health organizations, and to warn the public. Activate the Emergency Operations Center If it is concluded that a Declaration of Emergency or Governor's compelled evacuation order pursuant to Section 5 of Public Act 390 of 1976 is necessary or probable, the County Administrator and the Chair of the Board of Commissioners will be consulted immediately. Any protective action recommendations (evacuation or in-place sheltering) will be based on the following determinations made by the Emergency Coordinator in conjunction with the Incident Commander: 1. Physical properties of the chemical(s) or agent(s) released 2. Toxicological risk of the substance(s) on humans 3. Container or vessel design and the rate of release 4. Responder time required to confine or contain substance 5. Current weather conditions including wind, temperature, etc. 6. Affected populations including those who are more vulnerable 7. Time-of-day, traffic conditions, and special events underway 8. Accessibility of transportation systems and routes 9. Efficiency and location of available public warning systems Should evacuation be necessary to insure adequate protection of the public, any evacuation routes established shall be determined based on the following considerations: 1. Incident location and severity of release 2. Plume dispersion volume, concentration, direction and elevation 3. Population densities and location of vulnerable populations 4. Time-of-day, traffic and road conditions, and special events 5. Evacuation zone accessibility to secondary and primary roads 6. Locations of available shelter locations relative to the incident 7. Availability of police personnel to direct traffic flow Response Guidelines Category A Incident - The Emergency Coordinator or designee shall immediately initiate an emergency response from the local Fire and Police departments for any spill or active leak of a confirmed hazardous material or an unknown potentially hazardous material. The Emergency Coordinator may immediately respond to the scene, or monitor the situation via radio or telephone. If an incident commander on the scene requests additional assistance, and the incident does not fall into one of the categories below, the Emergency Coordinator or designee shall respond and coordinate activities 4

with the incident commander. Other county and state departments may be called upon to assist pursuant to county and state policies. Category B Incident - The Emergency Coordinator or designee shall immediately initiate an emergency response from the local Fire and Police departments for spills or releases of gasoline, diesel, lubrication oils, or any identified non-hazardous material. If an incident commander on the scene requests additional assistance, the Emergency Coordinator or designee shall notify: The Washtenaw County Water Resources Commissioner s Office (based on the current on-call schedule) for response to incidents that occur in county designated drains. This office will also serve as an information resource to other agencies in regard to surface water related incidents that do not meet response criteria. County employees responding to this incident category must be trained to the operations level. - OR - The Michigan Department of Environmental Quality for all other Category B spills and releases. Category C Incident - The Emergency Coordinator or designee shall immediately initiate an emergency response from the local Fire and Police departments for any reports of abandoned containers of potentially hazardous materials. If the containers are found to be leaking hazardous materials, the incident should be handled by the local fire department and Hazardous Materials Response Team. If an incident commander on the scene requests additional assistance, and the incident does not fall into Category B above, the Emergency Coordinator or designee shall respond and coordinate activities with the incident commander. Other county and state departments may be called upon to assist pursuant to county and state policies. If the first responders have determined that the containers are not leaking, the response agency should be requested to secure the scene with barrier tape, if possible, and provide an accurate location and accounting of the containers. The incident will be turned over to the Department of Natural Resources and Environment for remediation. Office of the Water Resources Commissioner The following response actions will be performed by staff of the Water Resources Commissioner s office: A. Provide assistance to environmental incidents that occur on or in county drains on a 24-hour basis. B. Serve as a resource and provide information to other agencies in regard to surface water related incidents that do not meet paragraph A criteria. C. Provide notification to the Michigan Department of Environmental Quality when responding to environmental incidents. 5

Water Resources Commissioner s Office response will be limited to gathering information and supporting the Michigan Department of Environmental Quality and other agencies regarding surface water flow patterns. For incidents involving enclosed county drains, where the MDNRE does not respond, staff from the Water Resources Commissioner s office will assume responsibility and arrange for appropriate mitigation. The Water Resources Commissioner s staff will not: Respond to all non-county drain related environmental incidents on an afterhours basis. Respond to environmental incidents for the purpose of taking over from the local fire department, law enforcement agency, or other first responder organization. Perform, supervise, or otherwise handle environmental mitigation or cleanup operations. Department of Public Health The following response actions will be performed by staff of the Department of Public Health: A. Provide support to the Michigan Department of Environmental Quality in the mitigation of category B and C incidents during normal business hours assessed by the Emergency Services Division as not constituting an immediate threat to human health; and providing Sheriff Emergency Services with an updated fan out phone list for use when a category A incident occurs after hours. B. Provide information to the Emergency Services Division on hazardous material storage at fixed facilities. C. Provide support and assistance to the Michigan Department of Environmental Quality to ensure that required clean-up has occurred at the site of environmental incidents. D. Provide assistance as requested by the Washtenaw County Hazardous Materials Response Team. E. Make requests for assistance from the U.S. Environmental Protection Agency to provide resources to help mitigate hazardous material incidents either affecting or with the potential to affect water resources (if such a request has not already been made by the Incident Commander, HazMat Team, or Sheriff Emergency Services). F. Make recommendations and provide assistance and support to the Incident 6

Commander, HazMat Team, and Sheriff Emergency Services on any actions, evacuations, and/or Public Health Advisories necessary to protect public health. G. Provide follow-up on residential mercury spills and clean-up of clandestine methylamphetamine operations. ENVIRONMENTAL EMERGENCY COSTS In the event that an environmental or hazardous materials incident poses a serious threat to the health or safety of the public or the environment, and if the responsible party can not be identified, the following personnel have authority to authorize work orders for the amounts specified: Position Department Amount Environmental Health Supervisor Public Health Up to $10,000 Director of Field Services W.R. Commissioner Up to $10,000 Coordinator WCSO Emergency Svcs. Up to $10,000 Director Public Health Up to $25,000 Director WCSO Emergency Svcs. Up to $25,000 W.R. Commissioner/Chief Deputy W.R. Commissioner Up to $25,000 County Administrator Administration Up to $50,000 Chair Board of Commissioners $50,000 + Verbal authorization from any of the above persons is acceptable to execute an emergency clean-up contract. The county s approved and contracted environmental remediation firm should be used. 7