THREAT DETERMINED to be ‘POSSIBLE’
OBJECTIVE: Attempt to determine whether the contamination threat is “Credible” or not within TWO to EIGHT hours of the time the threat was deemed “Possible”. A threat is characterized as “Credible” when information collected during the investigation indicates contamination is likely. (Obviously, it won’t always be possible to make this determination within this time frame, depending on the exact circumstances and the amount of information available.)
Ensure Incident Command Staff are working together and communicating; developing an initial Incident Action Plan and scheduling briefings as needed.
Care should be taken not to overreact. Generally, operational response actions that will negatively affect customers should not be implemented at this point. If containment, isolation, or some other “aggressive” actions can be accomplished without negatively affecting customers, however, they should be considered.
Continue investigating; attempt to rule out the most likely reasons or causes for the threat warning first.
Continue developing and implementing sampling strategies.
Consider notifications to DHEC, law enforcement, etc., as appropriate.
Prepare to implement the Emergency Communications Plan if necessary.
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THREAT DETERMINED to be ‘CREDIBLE’
OBJECTIVE: Attempt to determine whether contamination can be “Confirmed” or not as quickly as possible. A threat is characterized as “Confirmed” when information collected during the investigation indicates contamination has definitely occurred.
Ensure Incident Command Staff continue working together and communicating; updating Incident Action Plans and scheduling briefings as needed.
Consider more aggressive operational response actions, balancing the likelihood of actual contamination, the possible consequences of contamination, and the negative impact to customer from any response actions.
Consider issuing a precautionary Boil Water Advisory. (Generally, this decision should be made in consult with DHEC.)
Continue investigating, sampling, and making appropriate notifications.
Begin developing response plans in the event contamination is “confirmed”.
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THREAT IS ‘CONFIRMED’
OBJECTIVE: Implement full response actions as required to protect public health and restore normal system operations as quickly as possible.
Fully implement the Emergency Communications Plan, and ensure that all appropriate notifications have been made.
Implement appropriately aggressive operational response actions in order to contain, isolate, and remove the contamination.
Consider alternative water supplies if customers or areas will be without water service.
Continue to work closely with DHEC, law enforcement, and other support and/or emergency management agencies.
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REMEDIATION / RECOVERY
The specific remediation and recovery activities required will be determined by the exact type and amount of contamination. Remediation action plans must be closely coordinated with DHEC and can be as simple as flushing the affected system or as complex as abandoning and replacing the affected system.
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FOLLOW-UP
Safety Manager shall conduct a Critique of all incidents classified as Level 2 or higher, and shall properly document and follow-up on all findings and resulting corrective actions and/or recommendations.
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Hazardous Material Release
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SITUATION
GSWSA utilizes a wide variety of chemicals and materials that, if released or used incorrectly, could create physical and/or health hazards. While any of these products are capable of causing problems under the right conditions (propane, gasoline, etc.), the primary chemicals of concern are chlorine and anhydrous ammonia.
Both Wastewater Treatment Plants utilize chlorine in One-Ton cylinders. When full, these cylinders contain 2,000 pounds of liquid chlorine under pressure. A catastrophic, worst-case release could, according to air modeling, travel a maximum distance of up to 1.5 miles from the source of the release.
The water treatment plant uses chlorine in one hundred and fifty pound cylinders. When full, these cylinders contain 150 pounds of liquid chlorine under pressure. A catastrophic, worst-case release could, according to air modeling, travel a maximum distance of up to 0.9 miles.
The water treatment Plant uses anhydrous ammonia in one hundred pound cylinders. When full, these cylinders contain 100 pounds of liquid anhydrous ammonia under pressure. A catastrophic, worst-case release could, according to air modeling, travel a maximum distance of up to 700 feet.
All GSWSA chlorine and ammonia feed systems withdraw gas from the gas-space at the top of the cylinder, and this gas is introduced into a water stream to create a very strong chlorine or ammonia solution. This solution is then introduced into the treatment process at the desired locations
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THREAT or HAZARD INFORMATION
CHLORINE
Chlorine gas is one-and-one-half times heavier than air, so it tends to stay near the floor or ground, and settles into low-lying areas.
Chlorine is highly aggressive in the presence of moisture, and will react with the moisture in your eyes, mouth, nose, lungs, and even on your skin.
Even minor exposure to chlorine gas can irritate the lungs and respiratory system, and can lead to delayed complications.
One volume of liquid chlorine (for example, one cubic foot) not under pressure and at normal room temperature, will rapidly vaporize (turn to gas) into 460 volumes of pure chlorine gas (for example, 460 cubic feet).
Liquid chlorine is extremely cold, and will cause severe burns if it comes in contact with the skin.
Chlorine is not flammable, but it is an oxidizer, so it does support combustion the same way oxygen does (makes things burn easier and better).
AMMONIA
Ammonia gas is 40% lighter than air, so it tends to rise.
Ammonia is highly aggressive in the presence of moisture, and will react with the moisture in your eyes, mouth, nose, lungs, and even on your skin.
Even minor exposure to ammonia gas can irritate the lungs and respiratory system, and can lead to delayed complications.
Liquid ammonia is extremely cold, and will cause severe burns if it comes in contact with the skin.
CONCEPT of OPERATIONS
Refer to the GSWSA Safety Manual for basic safety information and routine handling procedures. For the one-ton cylinders, also refer to the Process Safety Management (PSM) Program and Risk Management Program (RMP).
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HAZARDOUS MATERIALS (HAZ MAT) INCIDENT SEVERITY LEVELS
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HAZ MAT
LEVEL
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SEVERITY
LEVEL
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DESCRIPTION and EXAMPLES
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1
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Standard
“Emergency”
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Indicates an incident with a very minimal degree of hazard or danger involved, and can be safely handled by properly trained, properly equipped personnel already on scene.
EXAMPLE: After connecting a new chlorine / ammonia cylinder, a small leak is detected at the lead gasket.
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2
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Minor
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Indicates an incident with a minor degree danger; can normally be safely handled by properly trained, properly equipped personnel already on scene.
EXAMPLE: A small leak on chlorine gas feed tubing.
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3
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Moderate
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Indicates an incident with a moderate degree of danger; will generally require an “emergency response” by trained and equipped Haz Mat Technicians; may require Fire Department Haz Mat Team support and assistance.
EXAMPLE: A leaking fusible plug on a chlorine cylinder.
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4
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Serious
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Indicates an incident with a serious degree of danger; will require an “emergency response” and Fire Department Haz Mat Team; may require public notification and/or evacuation.
EXAMPLE: Punctured or ruptured cylinder; valve or valve stem blowout.
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All chlorine and ammonia cylinders are stored and utilized in completely enclosed chemical feed rooms, which will help to contain a release should one occur.
All locations also have Leak Detectors, which will detect any release of chemical into the chemical feed room and activate an alarm light and buzzer at the chemical room.
All Leak Detectors are also connected to SCADA (Supervisory Control and Data Acquisition), or telemetry. When an alarm condition occurs, in addition to the local alarm at the chemical room, the alarm also shows up at the Dispatch Center / Control Room at the Operations Center, and is sent to the “On-Call” Plant Operator’s pager.
At the Wastewater Treatment Plants, a Leak Detector alarm also activates pneumatic (air operated) valves that are connected to each cylinder, automatically shutting off the flow of chlorine gas into the feed tubing and supply piping.
A Leak Detector alarm at a Wastewater Treatment Plant Chlorine Room will also activate a Scrubber System, which draws air out of the Chlorine Room, and passes it through a neutralizing agent before releasing it to the atmosphere.
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EMERGENCY PROCEDURES
GENERAL
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Notify and evacuate any personnel potentially in danger
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Isolate the area, to prevent others from entering the hazardous area
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If necessary or appropriate, move upwind to a safe area until assistance arrives
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If the releases poses any risk to the general public, advise emergency responders
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All personnel actively involved with an “emergency response” to a release, whether GSWSA employees or emergency services agencies, must be properly trained, qualified, and equipped – in accordance with OSHA 29 CFR 1910.120.
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Take no action that could jeopardize your safety or that of your co-workers, community, or the environment.
REPORTING
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All Haz Mat Level 2, 3, or 4 incidents shall be immediately reported to the Plant Supervisor, Chief of Utility Operations, Director of Fleet, Facilities, and Emergency Services, and Safety Manager.
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All Haz Mat Level 3 or 4 incidents, or any release incident resulting in injury, shall be promptly reported to the CEO and the Chief of Utility Operations.
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Any release potentially affecting the general public shall be immediately reported to the Horry County Fire Department.
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A chlorine release of 100 pounds or more must be reported to the SARA National Emergency Response Center at 1-800-424-8802.
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A spill that poses a threat to the environment must be reported the Department of Health and Environmental Control (DHEC) at 1-800-555-1212.
SPECIAL CONSIDERATIONS
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Quickly evaluate the wind direction in any release incident. That will dictate what locations are in danger, and what areas are safe.
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Consider the flammability of the spilled / released chemical. Be aware of potential ignition sources, such as vehicles or equipment operating nearby.
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Be aware of the potential for spilled or leaking chemicals to come in contact with other chemicals or materials, which may form even more hazardous compounds than the original chemical, or may result in a violent chemical reaction. For example, HTH, or dry granulated chlorine, will spontaneously combust (suddenly burst into flames) upon contact with many petroleum products.
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FOLLOW-UP
Safety Manager shall investigate all Haz Mat Level 2, 3, or 4 incidents, and shall properly document and follow-up on all findings and resulting corrective actions and/or recommendations.
Confined Space Emergency
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SITUATION
GSWSA employees routinely need to enter and work in locations that meet the Occupational Safety and Health Administration’s (OSHA) definition of a “confined space.” Typical examples include wastewater manholes, Wastewater Lift Station Wet Wells, and water storage tanks.
These spaces contain certain inherent risks, and the potential exists for various emergencies to occur while employees are in them.
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THREAT or HAZARD INFORMATION
Most confined spaces have the potential for a hazardous atmosphere (unsafe air), including toxic gases, flammable gases, and low oxygen content, which can all occur suddenly and without warning.
Many confined spaces also have the potential for physical hazards such as moving equipment or machinery, energized electrical equipment, falling objects, sharp objects, or biological hazards.
Environmental hazards are also frequently a concern, including high humidity, high temperature, low light conditions, and excessive noise.
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CONCEPT of OPERATIONS
Refer to the GSWSA Safety Manual for detailed procedures and requirements for confined space entry operations in accordance with OSHA 29 CFR 1910.146.
Every “Entrant” going into a Permit Required Confined Space shall wear a full body harness with an attached Retrieval Line.
For confined spaces five (5) feet or deeper, a mechanical means to retrieve the Entrant must also be implemented.
The air in the space must be tested before and during all entry operations.
An “Attendant” must be designated to stand by outside the space and monitor the safety of the Entrant(s) at all times.
Properly trained and equipped “rescue services” must be available during all confined space entry operations.
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EMERGENCY PROCEDURES
Should an emergency occur within the space, the Attendant shall immediately notify the designated rescue services, Horry County Fire Department, Horry County EMS, Horry County Rescue Squad.
The Safety Manager shall be notified immediately, and shall ensure the CEO and Chief of Utilities Operations are promptly informed.
Internal notification can be accomplished over the two-way radio. External notifications may be made directly by radio phone patch or cell phone, or GSWSA Dispatch may be requested to notify external emergency personnel.
The Attendant shall NOT enter the space, unless properly trained and equipped for rescue, and as part of an organized and coordinated rescue operation.
The Attendant shall attempt a “non-entry rescue” by hoisting or pulling the Entrant out of the space by the Retrieval Line attached to their harness.
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FOLLOW-UP
The Safety Manager shall investigate all confined space incidents, and shall properly document and follow-up on all findings and resulting corrective actions and/or recommendations.
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Trench / Excavation Collapse
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SITUATION
GSWSA employees routinely need to enter and work in trenches and excavations in order to maintain the water lines, wastewater lines, valves, fire hydrants, water meters, etc., throughout the water and wastewater systems.
Trenches and excavations present certain inherent hazards, and the potential exists for various emergencies to occur while employees are in them, up to and including cave-in, or collapse, of the excavation walls.
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THREAT or HAZARD INFORMATION
Trenching and excavation work sites can present numerous hazards. These may include, but are not limited to:
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collapse or cave-in
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toxic gases
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flammable gases
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low oxygen content
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contact with electrical utilities or wiring
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flooding / drowning / engulfment
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passing traffic
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vehicles / equipment / heavy loads falling in
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CONCEPT of OPERATIONS
Refer to the GSWSA Safety Manual for detailed procedures and requirements for trenching and excavation in accordance with OSHA 29 CFR 1926.650, 651 and 652.
Excavations four (4) feet or deeper require a ladder or some other means for employees to enter and exit the hole.
Excavations five (5) feet or deeper require either sloping the walls to a safe angle, or, installing shoring or shielding to prevent wall collapse.
Spoil piles, and all other heavy loads, must be kept at least two (2) feet away from the edge of the hole.
Excavations in locations subject to atmospheric hazards, such as near underground fuel storage tanks, in marshy / swampy areas, etc., require testing of the air in the hole before employees enter to work.
A “Competent Person” (trained and qualified employee) must evaluate the excavation and determine it is safe before anyone enters, and as needed during the work.
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EMERGENCY PROCEDURES
Should an emergency occur within a trench or excavation, personnel on site shall immediately activate emergency services, either directly by radio phone patch or cell phone, or GSWSA Dispatch may be requested to notify external emergency personnel.
The Safety Manager shall be notified immediately, and shall ensure the appropriate Division Chief and CEO are promptly informed.
DO NOT attempt to dig the person(s) out with a backhoe or excavator.
Stop all work activities, and move unnecessary personnel back at least 100 feet.
Secondary collapses are very common, so no one should enter the excavation until it is absolutely safe to do so. Generally this will require emergency shoring.
If the person is completely covered, try to identify where he/she was last know to be, to give rescue crews a starting point.
Take no action that could jeopardize your safety or that of your co-workers, community, or the environment.
Trench rescues are extremely dangerous, and can be very lengthy operations. It is not uncommon for a “simple” rescue to take 5 or 6 hours, and complex one 12 to 16 hours.
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FOLLOW-UP
The Safety Manager shall investigate all trench / excavation incidents, and shall properly document and follow-up on all findings and resulting corrective actions and/or recommendations.
Fire / Explosion
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SITUATION
GSWSA facilities are susceptible to the threat of fire, and possibly even explosion, from numerous potential causes.
Fires or explosions in the workplace can present significant risk to employees.
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THREAT or HAZARD INFORMATION
There are numerous conditions and work activities that create the potential for fire or explosion to occur. These may include, but are not limited to:
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malfunctioning or damaged electrical equipment
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overheating electrical equipment or appliances
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“Hot Work” (welding, cutting, brazing, etc.)
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sparks from grinding operations
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improper use or storage of flammable liquids / gases
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smoking near flammable / combustible materials
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chemical reaction from incompatible materials
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CONCEPT of OPERATIONS
Refer to the GSWSA Safety Manual for detailed procedures and requirements for fire prevention and fire safety in accordance with OSHA 29 CFR 1910.35 – 1910.39
All GSWSA facilities have Fire Extinguishers installed at locations and intervals meeting the requirements of the National Fire Protection Association (NFPA) Life Safety Code.
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EMERGENCY PROCEDURES
Any employee observing a fire of any kind shall immediately sound the alarm to warn others by either going themselves, or sending someone else, to activate one of the Fire Alarm Pull Stations.
Any employee who is properly trained may utilize Fire Extinguishers in an attempt to extinguish an incipient, or beginning stage, fire – as long as it can be done without risking one’s own personal safety. If it is not safe to attempt to use an extinguisher – DO NOT TRY IT. Warn others by activating the alarm and evacuate.
Upon hearing the Fire Alarm, all personnel shall promptly evacuate in accordance with the Evacuation Plan in Appendix 12.
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FOLLOW-UP
Safety Manager shall investigate all fire / explosion incidents, and shall properly document and follow-up on all findings and resulting corrective actions and/or recommendations.
Bomb Threat / Suspicious Package
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SITUATION
GSWSA facilities are susceptible to the threat of harmful devices, packages, or mail being used for the purpose of coercing, intimidating, or causing harm.
GSWSA is also susceptible to persons make the “threat” of using such devices, packages, or mail for the purpose of coercing, intimidating, or causing harm.
This Guideline applies to all suspicious packages, regardless of whether the suspected (or confirmed) hazard is explosive, chemical, biological, etc.
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THREAT or HAZARD INFORMATION
Explosive: Explosive devices and materials come in many different forms, and can be arranged into an endless variety of shapes, sizes, and configurations. Many kinds of explosives are relatively easy to get and easy to use.
Biological: While it would require a great deal more expertise and sophistication, it is possible that someone wishing to cause harm to GSWSA could introduce biological agents into the workplace. These types of agents are much more effective being introduced into food, water, or sprayed into the air, but could potentially just be sent in a package. Examples include anthrax, cholera, smallpox, ricin, and botulism.
Chemical: While extremely unlikely, it is possible that chemical agents could be introduced into the workplace through packages. Most of these require sophisticated techniques and protective equipment to handle and put into place. Examples include nerve agents (sarin, VX), cyanide, blister agents (mustard, lewisite), and pulmonary agents (chlorine, phosgene),
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