Generic Emergency Response Plan for Chlorinated … · Generic Emergency Response Plan for...

Generic Emergency Response Plan for Chlorinated Water

A Guide for Integrating A Response To Chlorinated Water Spills into Existing Municipal Emergency Planning

Prepared For:

Greater Vancouver Regional District Drinking Water Treatment Program

Prepared By:

ENKON Environmental Limited Suite 525 - 1207 Douglas Street

Victoria, B.C. V8W 2E7

&

LaMorte & Associates Suite 210 - 645 Fort Street Victoria, B.C. V8W 2N7

&

Norecol, Dames & Moore, Inc. Suite 1900 - 650 West Georgia Street

Vancouver, BC V6B 4N7

November, 1997


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EXECUTIVE SUMMARY The purpose of this document is to provide a generic approach for emergency response planning to spills of chlorinated tap water. This document provides guidance on how municipalities can develop their own emergency response plan for spills of chlorinated water. Eight principal response requirements have been identified as part of the general response strategy for an accidental spill of chlorinated tap water. The eight responses include: • record notification • evaluate situation • contact agencies and others • control flow/contain spill • neutralize chlorine • monitor chlorine • document actions and report to authorities In order to effectively address the eight principal response requirements, Water Operations Supervisors should identify and review their existing municipal strategies and polices and suggest how they may be adapted to formally recognize the need to prevent and respond to an accidental release of chlorinated tap water. In this generic plan, the GVRD has designated an Emergency Planning Coordinator as one who would be responsible for coordinating the efforts needed to ensure preparedness. The Emergency Planning Coordinator job for an accidental spill of chlorinated tap water should be undertaken by the Water Operations Supervisor. The Emergency Planning Coordinator should report to an Emergency Planning Committee for that municipality. Additional responsibilities in the event of an accidental release of chlorinated tap water should be assigned to a dispatcher, the operations support staff, and field crews. In each case, the responsibilities should be clearly outlined and personnel should be trained in the response planning and techniques. Training will be an integral part to ensuring that an emergency response plan is effectively administered. Once the personnel are trained and aware of their responsibilities, they should also be equipped with the proper equipment to respond to an accidental spill. This should include equipment necessary to suspend the flow of chlorinated water, safety equipment, field kits for measuring residual chlorine, dechlorinating agent(s), and recording material such as cameras and record sheets.


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TABLE OF CONTENTS EXECUTIVE SUMMARY......................................................................................................................................................................ii INTRODUCTION ...................................................................................................................................................................................1

1.1 Purpose.................................................................................................................................................................................1 1.2 Scope....................................................................................................................................................................................2 1.3 Approach..............................................................................................................................................................................2 1.4 Target Audience...................................................................................................................................................................3

RESPONSE PROCEDURES...................................................................................................................................................................4 2.1 Record Notification..............................................................................................................................................................5 2.2 Evaluate Situation ................................................................................................................................................................5 Table 2-2. Emergency Call Report Form ........................................................................................................................................6 2.3 Contact Agencies and Others ...............................................................................................................................................8 Table 2-3. Key Factors in Evaluating the Situation.........................................................................................................................9 2.4 Control Flow ......................................................................................................................................................................10 2.5 Contain Spill ......................................................................................................................................................................11 2.6 Neutralize Chlorine ............................................................................................................................................................12 Table 2-6. Sample Field Dechlorination Record Form .................................................................................................................15 2.7 Monitor Chlorine................................................................................................................................................................17 2.8 Document Actions and Report to Authorities ....................................................................................................................18

ORGANIZATION AND DATA COLLECTION..................................................................................................................................20 3.1 Environmental Protection Policy........................................................................................................................................20 3.2 Emergency Planning Coordinator ......................................................................................................................................20 Table 3-1. Sample Environmental Policy for Chlorinated Water..................................................................................................21 3.3 Planning Committee ...........................................................................................................................................................22 3.4 Risk Assessment.................................................................................................................................................................22 3.5 Appropriate Laws and Regulations ....................................................................................................................................23 3.6 Roles and Responsibilities .................................................................................................................................................23 3.7 Resources ...........................................................................................................................................................................29 3.8 Communication ..................................................................................................................................................................31

PLAN ADMINISTRATION..................................................................................................................................................................33 4.1 Training..............................................................................................................................................................................33 4.2 Testing................................................................................................................................................................................34 4.3 Updating.............................................................................................................................................................................34 4.4 Approval ............................................................................................................................................................................35 4.5 Audit ..................................................................................................................................................................................35

APPENDICES .......................................................................................................................................................................................36 APPENDIX A - RISK ASSESSMENT............................................................................................................37

A.1 Chlorine Concentrations.....................................................................................................................................................37 A.2 Water Storage and Delivery Systems .................................................................................................................................39 A.3 Local Environment.............................................................................................................................................................41 A.4 Risks and Types of Events .................................................................................................................................................41

APPENDIX B - LEGAL REVIEW ..................................................................................................................44 B.1 Federal Legislation.............................................................................................................................................................44 B.2 Provincial Criteria ..............................................................................................................................................................46

APPENDIX C - DEFINITIONS.......................................................................................................................49 REFERENCES ......................................................................................................................................................................................51


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INTRODUCTION

Based on public input, in June, 1994, the GVRD Board selected the use of chlorine solution for secondary disinfection of drinking water. Ozone cannot be used because it breaks down too quickly. The public said they preferred the use of chlorine over chloramine because it presents a lower risk to the environment - even though chlorine will cost more and may add a chlorine taste and odour to the water.

In choosing chlorine over chloramine, the GVRD has already provided its water users with a first step in mitigating the impacts of potable water discharges by selecting a secondary disinfectant with a lower potential impact.

Responding to unintentional releases of chlorinated water is essential in order to protect the environment and limit exposure to legal action. However, it must be made clear that regardless of good response planning and implementation, large spills near fish habitat can be expected to cause impacts and may result in legal action. This document provides municipalities in the Greater Vancouver Regional District with a model for emergency management functions as they relate to spills of chlorinated tap water.

1.1 Purpose This Generic Emergency Response Plan offers general procedures for responding to releases of tap water, such as occurs with a water line leak or break, and outlines organizational requirements to effectively complete these procedures. This document is meant only as a guide. Each municipality must adopt their own emergency response plan. The GVRD has published this guide in combination with a series of Guidelines that provide specific management measures for releases of chlorinated tap water, including intentional releases. Guidelines are available for the following categories of water use:

• Agricultural Water Use • Construction Water Use • Domestic Water Use • Industrial/Commercial Water Use • Municipal Water Use

The Greater Vancouver Water District (GVWD) and its member municipalities, listed in Table 1-1, use chlorine to treat all water distributed within their Lower Mainland service area. The GVWD undertakes this treatment as one measure to comply with the B.C. Safe Drinking Water Regulation, in effect October 1992. The Drinking Water Regulation requires that no sample of potable water contain any faecal coliform organisms and no more than 10 total coliform organisms per 100 mL, and that 90 percent of all samples collected within a 30-day period contain no coliform organisms. Not all water within the service area currently meets these standards. Chlorine is a powerful oxidant that kills and/or controls most harmful microorganisms. Chlorine is also,


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however, acutely toxic to fish and their food sources. The release of chlorinated water can result in environmental degradation even where the concentration of chlorine is very low. Federal and provincial environmental protection agencies enforce general provisions that prohibit the deposit of "deleterious substances" like chlorinated water, and courts may impose substantial penalties on violators (see Appendix B).

1.2 Scope This guide addresses the unintentional escape of tap water, not planned or controlled releases. Unintentional releases may occur with a leak or break in a pipe carrying chlorinated water. Controlled releases may occur under more predictable circumstances such as water main flushing. Other routine releases of tap water include direct discharge by industrial / commercial water users, draining of water mains for repairs, road flushing, hydrant flushing, and fire fighting. Procedures for preventing the release of tap water from these and other controlled activities may be found in the Municipal Water Use Guidelines.

1.3 Approach All member municipalities have developed emergency plans for a variety of hazards, including major fire, industrial accidents, spills of dangerous goods, and natural disasters. They maintain an emergency response policy, response procedure manuals, and emergency call-out lists. A designated Emergency Coordinator serves each municipality, usually operating through an established Emergency Planning Committee, and has defined roles and responsibilities throughout most municipal departments.

Table 1-1. Municipal Members of the Greater Vancouver Water District 1. Burnaby 2. Coquitlam 3. Delta 4. Langley, City of 5. Langley, Township of 6. Maple Ridge 7. New Westminster 8. North Vancouver, City of 9. North Vancouver, District of 10. Pitt Meadows 11. Port Coquitlam 12. Port Moody 13. Richmond 14. Surrey 15. U.E.L. 16. U.B.C. 17. Vancouver 18. West Vancouver


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Many municipal water operations departments have already developed procedures to deal with leaks and breaks in water lines. Some have systems and procedures in place within their Operations Departments, using police or fire department dispatch services for all calls outside the normal working day. All municipalities have access to standby operation staff, higher levels of decision-making authority, and any heavy equipment that may be required. Acknowledging the status of these plans and preparations, this guide offers two benefits. First, it suggests steps for incorporating tap water release response procedures into existing municipal emergency plans. Second, it allows municipal operation managers to build new response plans specific to tap water, where needed. The format of this generic plan follows the national guidelines of the Canadian Standards Association (CSA), Emergency Planning for Industry, CAN/CSA-Z731-95. CSA created the standard to provide "minimum criteria for emergency planning and to provide guidance to owners and operators of private and public industrial facilities in the development of a plan for effective emergency preparedness and response" (CSA, May 1991). The standard is sufficiently broad in scope to embrace the protection of fish and fish habitat from spills of chlorinated water. To augment the CSA standard, the B.C. Environmental Emergency Services Branch developed Guidelines for Industry Emergency Response Contingency Plans in 1992. These guidelines were developed to promote comprehensive emergency plans by B.C. industries. As a generic guide to emergency procedures, this document should be viewed with caution. Successful response depends on the organization responsible for environmental protection. Readers should not assume that all acceptable practices, equipment, procedures, or technical summaries are included here. Some information may be superseded by federal, provincial, or local requirements. This document, therefore, must be customized to each area or municipality where chlorinated water could unintentionally enter the aquatic environment.

1.4 Target Audience The GVRD developed this generic plan for use by municipal officials with responsibility for delivering chlorinated water in the GVRD service area. Specifically, this document advises Water Operations Supervisors on how to integrate concern for chlorinated water releases into existing municipal emergency response plans and operations. Section 2.0 of this document discusses the minimum response procedures that need to be in place to effectively manage spills of tap water. Section 3.0 describes organizational and data collection requirements while Section 4.0 addresses administrative issues such as training.


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RESPONSE PROCEDURES Responding to unintentional releases of chlorinated water requires a methodical series of actions, regardless of the type or location of release. In this section, eight key steps are outlined that are common to most response efforts. They will provide an overview of the general response strategy. Where appropriate, crews may need to control the flow, contain the spill, and neutralize chlorine simultaneously. A checklist of the eight principal response procedures is highlighted in Table 2-1. Each step is fully described in the subsections that follow.

Table 2-1. Response Procedures for Environmental Emergencies Involving Chlorinated Water

• Record Notification • Evaluate Situation • Contact Others • Control Flow • Contain Spill • Neutralize Chlorine • Monitor Chlorine • Document Actions & Report to Authorities


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2.1 Record Notification Notification of a leak or break may come from either inside or outside the organization. All municipal employees have the responsibility to immediately contact the designated control point (ie. dispatch) when they discover a leak. Many breaks are reported by the general public by telephone. A sudden drop in pressure may alert crews to a leak or a break. Upon receiving notice of a water release, dispatch should record the relevant information on a standard incident report form, such as the one suggested in Table 2-2. The suggested form highlights the type of information that should be collected during an initial notification, including the location and rate of water flow. In addition, the form offers a prompt for subsequent calls to key response agencies. Table 2-2 offers steps in completing the form. After taking relevant information from the initial call, the municipal dispatcher should contact the on-call Official-in-Charge (OIC) of the chlorinated water response. While this position may vary from one municipality to the next, it refers to the person in charge of the water system at the time of the release. The municipal OIC might be the Water Operations Supervisor, the Manager of Operations, the Director of Engineering Operations, or other similar position. The Official-in-Charge will determine the appropriate response. Where a leak or break is reported for a water line managed by the GVWD, the dispatcher will usually report the incident directly to GVRD control at the Lake City Operations Center.

2.2 Evaluate Situation Under the federal Fisheries Act, municipalities may be fined for failing to initiate remedial action following the release of chlorinated water. If charges are brought under the Fisheries Act because of a spill into fish habitat, the court will consider actions taken to mitigate damage. An accurate assessment of each leak situation is needed to define critical issues before taking the appropriate action. This evaluation is dynamic and the incident may require ongoing assessment to ensure the most appropriate remedial measures are taken. The Official-in-Charge at the time of the emergency is responsible for evaluating the situation. The OIC may consult with on-duty staff, management, and the Water Spill Response Planning System (WSRPS) (GVRD, 1997) during the assessment and should utilize DFO knowledge and expertise regarding potential dangers posed to local fish-bearing waters.


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Table 2-2. Emergency Call Report Form Date

Time of Call

Name of Person Calling

Telephone Number (for call-back)

Callers Location

Caller's Address

Name and Telephone Number of Contact at Scene of the Release (if different than above) Location of Release

Approximate Quantity or Rate of Leak

Source of Release: GVWD Main Reservoir / Tank Municipal Main Service Line

Date and Time of First Observation

Directions to Scene CONTACTS

Phone No. Person Contacted/Report No. Time Operations Supervisor

am/pm Fisheries & Oceans 666-3500

am/pm Environment Canada 666-6100

am/pm P.E.P. and MELP 1-800-663-3456

am/pm GVWD Control 444-8401

am/pm Others Potentially

am/pm Affected (eg, fish farms)

am/pm

Name of Person Completing this Form _______________________ Comments:


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Date, Time of Call Record the date and time the initial call was

received. Name of Person Calling, Telephone Number(for call-back)

Record the name and phone number of the person reporting the event.

Caller's Location, Address Ask for the current location of the caller and

address for later follow up. Name and Telephone Number of Contact atScene of the Release (if different thanabove)

If other individuals are attending the scene, record their name, position, organization, and means of contact.

Source of Release If known, record the source of the leak as a

transmission line, storage reservoir or tank, distribution line, or individual service line.

Approximate Quantity or Rate of Leak Ask for comments on the approximate

volume of water released and the flow rate. For example, is it equivalent to a garden hose, a fire hose, or larger.

Location of Release It is important to clearly identify the location

of the leak or break. Ask the caller about where the water is going.

Date and Time of First Observation Determine the time of the call and when the

leak was first observed. Directions to Scene Obtain the nearest cross streets or other clear

identification. Contacts Record the calls to your manager and the

environmental agencies. Name of Person Completing this Form Print your name.


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The evaluation should allow the OIC to determine the following points:

• Severity of incident (minor, moderate, or major). Determine if there is any danger of the water entering any aquatic habitat.

• The type of actions that are appropriate. • Contacts, either in-house or in external organizations. • The equipment that is needed. • How to ensure personnel safety. • Action priorities.

Upon notification of a leak or break, the OIC may attend the scene to better evaluate the circumstances, if practical to do so. Key factors to consider in evaluating the situation are highlighted in Table 2-3. Under the direction of the OIC, emergency responders may be required to perform a number of tasks. The OIC alerts the required crews to the need for response, indicating where to assemble, what gear is appropriate, and any other service providers to notify. All crew members must report to and follow the directions of the OIC. The OIC should keep in touch with dispatch by way of telephone or radio.

2.3 Contact Agencies and Others The Official-in-Charge will determine if the municipality should report the spill immediately to environmental agencies. Often, the dispatcher is called upon to complete this task, using the Emergency Call Report Form to record the contacts and time. It should be noted that the different agencies have an agreement that if one party receives notification, they will inform other pertinent agencies of the situation. Field representatives of federal and provincial environmental protection agencies may play a role in responding to an event. They may advise the Official-in-Charge to contact other agencies, or to document actions taken. Even if they cannot attend the scene, these specialists are able to advise responders on the sensitivity of habitats endangered, the commercial services that may be available to provide assistance, and the legal requirements for action.


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Table 2-3. Key Factors in Evaluating the Situation

Volume, Flow Rate Consider evidence of the actual flow rate and the volume

of water released so far. Location Using the Water Spill Response Planning System

(WSRPS), locate nearby fish environments and likely entry points to the receiving environment. Use the WSRP System to determine if there is any possibility of danger of water entering any aquatic habitat. If so, notify Fisheries & Oceans Canada first and then PEP and Environment Canada and initiate emergency dechlorination. If in doubt, assume fish are present, notify, and dechlorinate.

Ability to Control Flow The location of the release site will also help determine

your ability to control the flow of the release. Consider existing water mains, stormwater systems, contingency berms, bypass main. Note, however, that shutting off the flow completely may contaminate a main line and will require disinfection.

Chlorine Concentration This information is useful in determining potential

response procedures, such as the amount of sodium thiosulphate required for neutralization. If possible, determine the chlorine concentration using a field test measuring device at the site to confirm your assessment.


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If there is a potential for environmental impact, the OIC should ensure notification of the following agencies as soon as possible:

• Municipal Official in Charge, such as the Water Operations Supervisor • Department of Fisheries and Oceans (Fisheries Radio Room at 666-3500) • Environment Canada (24-hour number 666-6100) • Provincial Emergency Program (and thereby Ministry of Environment, Lands and Parks

at 1-800-663-3456) • Any individuals or operations (e.g., fish farms) that might be affected • GVWD Control Room (Lake City Operations: telephone 444-8401) if the break involves

a GVWD transmission line Some leaks can be handled readily by staff and resources already available near the site of the incident, and may not require the involvement of senior management or special emergency response teams. Other events may prove beyond the initial capability of field crews and will likely require additional resources, expertise, coordination, and formal management. The Official in Charge should decide whether to call off-duty personnel to the scene to help with an emergency, and let dispatch know of the need. Dispatch will usually initiate the call-out.

2.4 Control Flow One effective way of reducing environmental damage is to restrict the flow of treated water. Controlling the flow reduces the magnitude of environmental impact should the flow reach a waterway important to fish. Municipalities should design a procedure for immediately contacting the appropriate officials and for quickly lowering the pressure on the affected main or, if absolutely necessary, halting flow completely. Closing a water main, however, may cause potentially serious contamination. After structural integrity, positive pressure in a water main is the greatest barrier to the intrusion of contaminated material. When a main line is broken, positive pressure in the main is the only barrier to intrusion of impurities. Contamination would then require disinfection of the main using a high strength disinfectant as per AWWA standards. As with every procedure, documentation is critical to the process and for reporting the incident. The OIC should ensure that all personnel keep good records of important steps taken to control the flow.


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2.5 Contain Spill Containing any released water goes hand-in-hand with controlling the flow. Containment buys time needed to evaluate the seriousness of the event, and enhances other response options, like neutralization. Any municipal employee discovering a leak should initiate steps to contain the spill if immediate action would provide some benefit without endangering personnel or slowing notification. This can reduce or prevent property damage. Containment involves halting the spread of treated water to prevent it from entering storm sewers, natural drainage areas, and environments important to fish. Consider the use of the following tools:

• Sand bags • Earth • Tarps • Plywood • Plastic sheets • Back hoe

Sand bags, small earth dams, or any similar measure may prove useful in containing or slowing the water flow. Crews should be advised to trap the released water behind a berm before it enters a stream, using sandbags or by using heavy equipment to build a berm as quickly as possible. The trapped water can then be dechlorinated. Section 5.2 of the Chlorine Monitoring and Dechlorinating Techniques Handbook (GVRD, 1997) offers additional options for controlling the flow, including the use of swales and ditches. Note, however, that even a small holding pond may surcharge the near-surface soils with water, and may result in flooded basements near the pond. Caution must be applied in locating such holding ponds, avoiding sand and gravel substrates in favour of clays or fine soils. The proper location of a holding pond depends on the judgement of qualified and trained staff. As an immediate response until containment is in place, field personnel should be advised to place one or two emergency dechlorination bags into the water flow. Again, field records on efforts to contain the spill are vitally important.


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2.6 Neutralize Chlorine The adverse effects of chlorinated tap water can be eliminated by neutralizing the chlorine before it enters habitat important to fish. These chemicals have been used to dechlorinate potable water in the field:

• Sodium bisulphite (NaHSO3) • Sodium sulphite (Na2SO3) • Sodium thiosulphate (Na2S2O3)

Sodium bisulphite and sodium sulphite are available in both powder and liquid form. Dechlorinating agents containing sulphites, however, can deplete the oxygen content of treated water, therefore sodium thiosulphate is the recommended choice. Reducing the oxygen content can lead to adverse impacts on biota in a creek or lake. Therefore, care must be taken when using these chemicals. Monitoring of the oxygen levels to ensure dissolved oxygen concentrations are not depleted may be warranted, especially in sensitive ecosystems. The GVWD staff uses sodium thiosulphate for dechlorination. Sodium thiosulphate is available in two forms:

• Anhydrous sodium thiosulphate (Na2S2O3). As the stronger of the two forms, anhydrous lasts longer but takes longer to dissolve.

• Pentahydrate sodium thiosulphate (Na2S2O3 • 5H2O). Weaker pound for pound, but the

pentahydrate version dissolves more easily. If crews cannot contain the released water using a berm or dam, they should place one or two dechlorination bags into the flow. Dechlorination bags consist of coarse-weave plastic or burlap bags containing solid cakes of sodium thiosulphate. Likewise, if the break occurs close to a stream and trapping the water is not possible, crews should quickly place a dechlorination bag downstream, close to the break. This will allow contact time before the water enters a ditch/creek. If necessary, a small amount of sodium thiosulphate crystals can be added directly to the discharge, before it enters the receiving environment. If chlorinated tap water enters a stream or ditch that leads to a watercourse, crews should toss one of the bags of sodium thiosulphate directly into the stream of water and anchor it with a rope. The bag should be kept in the main flow of water for the greatest effectiveness. In addition to using bags of sodium thiosulphate, the liquid form of this chemical can be used for dechlorination. This approach however, needs more preparation time and equipment at the site, and would not be typically used in an emergency response situation. Detailed procedures for this approach to


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dechlorination can be found in the Chlorine Monitoring and Dechlorination Techniques Handbook (GVRD, 1997). After dechlorination, field personnel may release the water to the receiving environment. Specific procedures may differ depending on the circumstances and location, as follows:

Receiving Waters. Water with a chlorine residual should not be discharged to a stream, river, or lake.

Storm Sewer. Crews should not release water with measurable levels of chlorine residual to the storm sewer system. Storm water systems are often directly connected with receiving waters important to fish.

Sanitary Sewers. Crews can discharge chlorinated water to sanitary sewers upon approval by officials of the affected facility. This is a safe course to follow if the volume is low or moderate and considerable distance separates the point of addition and the sewage treatment plant. However, if there is a large volume, e.g., with a reservoir or large main break, it is essential to contact the GVRD and/or municipal sewer crews to ensure sewage treatment plant operation would not be adversely affected by a mass of water and there is no risk to staff working in the sewer system.

If possible, neutralized water should not be released before it is checked for total residual chlorine with a field kit. Note, however, that most available field kits cannot measure accurate concentrations below 0.1 mg/L. However, they can detect lower concentrations of chlorine by a faint colour. In addition, some field kits, such as the DPD Indicator1, may suffer interference by oxidized forms of manganese and from iodine, ozone and chromium. The interfering compound reacts with the indicator to give a false positive reading, suggesting the presence of chlorine when there may be none. High sample colour and turbidity may also cause inaccurate readings. To compensate for this potential problem, responders should establish background readings using chlorine-free blanks. A chlorine-free sample can be made by agitating a sample to reduce the chlorine level, then checking for chlorine levels using the field kit. If this test produces a positive result, responders must take interference into account during the monitoring effort. With some kits, these false high background readings can be subtracted from the reading from a true sample. Crews should keep complete and legible records of how much dechlorinating agent is used, as well as

1 The water is collected in a sample tube and the indicator is added to this tube. The indicator is in the form of tablets

or powder used to dye water samples to a degree proportional to the chlorine content in the sample. When the water in the tube changes colour, the colour is compared to 9 or 10 colours present in similar smaller tubes located on a colour disk.


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the chlorine residual before and after dechlorination. Table 2-6 offers a sample record sheet to track the neutralization efforts. As a minimum, before the break is repaired and the main put back into service, the broken section of the main should be fully exposed. Responders should pump out any water in the excavation at the level of the main, and evaluate the situation. If the main must be put back into service and responders suspect contamination, the main should be isolated from the existing system and disinfected before being put back into service. Under most circumstances, it will be necessary to have municipal field crews carry out an emergency chlorination of the broken main. The AWWA Standard for Disinfection Water Mains (AWWA C651-86) should be followed and care must be taken to contain all chlorinated water.


Table 2-6. Sample Field Dechlorination Record Form

EMERGENCY RESPONSE RECORD Equipment: Emergency Equipment and Supplies Kit (see attached) Steps To Take:

1) Keep Records of:

Time of Break: (a.m./p.m.) Personnel on Site/agencies/companies:

Who has been contacted: PEP Yes ( ) No ( ) Department of Fisheries and Oceans Yes ( ) No ( ) Environment Canada Yes ( ) No ( )

Others:

Chlorine residual test results: use the attached table.

(be sure and state the units of measurement, time of measurement, make and model of measuring device)

Type of dechlorinating agent used (ie: bags of sodium thiosulphate):

Steps taken to minimize effect of break (any berming, stop flow etc.):

2) Is there any immediate danger to fish bearing streams?

Location of nearest outfall (stream name/water body etc):

RECORD OF DECHLORINATION ACTIVITIES

Date (m/d/y)

Location (Address)

Estimated Flow Rate of Water

(include units,ie:

gallons/minute)

Total Residual

Chlorine (TRC) Measured in

Water (mg/L)

Amount of

Dechlorinating Agent Added (# of Bags or

other)

pH

Measured in

Discharge Water

TRC Measured

in Discharge Water After

Dechlorinating Agent Added

TRC Measured

in Receiving Stream (note if

it is upstream or downstream)

Signature: Print Name: Date: Telephone Number (Supervisor’s Daytime #):


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2.7 Monitor Chlorine

Response crews should check their efforts to dechlorinate water flows by monitoring the chlorine concentration. Field analytical methods should measure the concentration of "total residual chlorine�, which is the sum of "free" available chlorine plus "combined" available chlorine. Combined available chlorine refers to the portion of chlorine that is present in chloramines, formed when chlorine is added to water that contains ammonia, and other specific nitrogenous compounds.

Beginning at the neutralization site, crews must check conditions throughout the flow, taking appropriate action to apply sodium thiosulphate or another dechlorination agent where needed. If no total residual chlorine is detected at one point, the crew should then move downstream to continue checking conditions.

Responders must keep checking for the absence of the total residual chlorine throughout the entire response time. If no chlorine residual is detectable, then the discharge should be safe for the environment in terms of residual chlorine.

Attempts to monitor chlorine in the field will encounter a problem with measuring to exact standards. The provincial criteria of 0.002 mg/L for Total Residual Chlorine (TRC) in receiving waters is not measurable even in the laboratory using the most sophisticated equipment. The sensitivity of field test kits is much less. HACH field kits, for example, can measure 0.1 mg/L at best. Low levels of chlorine (0.03 mg/L) can be detected, however, though not quantified, by a slight change in colour, therefore a pocket colorimeter is recommended to test for residual chlorine since it is slightly more sensitive than the HACH kit.

To monitor actual chlorine levels, responders should also look for and record any observations of dead or stressed fish, impacts to insects or other invertebrates, or other evidence of environmental damage. Measurements for chlorine levels should be taken upstream and downstream of where the flow enters the receiving waters. The upstream sample is important because it provides the necessary background information for comparison purposes.

When hazards are reduced to acceptable levels and the need for response has been resolved, the Official in Charge can permit the crews to stand-down from emergency status.


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2.8 Document Actions and Report to Authorities

The Official-in-Charge should ensure a written incident report is prepared as soon as possible after completing an investigation of each major incident. A succinct personal record or tactical response plan can be presented in court as the evidence of the "due diligence" municipal crews took in meeting their responsibilities and show that they have previous training in response situations. Taking photographs or video of an incident and the response steps is a good way to document municipal efforts to manage environmental risk.

An Incident Report Form is the basic document for describing the nature of the incident and the actions taken to effectively control it. Key elements to be considered in an incident report include the following:

• General description of the incident including the time of notification, time of arrival at the site, the time that

actions were taken and the time that the water flow was stemmed • Location of break • Flow from break • Agencies contacted • Staff or other persons present • Source and cause of the incident • Quantity and initial chlorine concentration of treated water released • Quantity of treated water neutralized and resultant chlorine concentration • Evidence of impact to fish-bearing waters • Description of the response, including personnel time and itemized costs • Suitability of the response structure, equipment, communications • Adequacy of training, spill containment and neutralization procedures • Recommendations for prevention and mitigating measures • Recommendations for improving response

A draft of the report should be circulated among members of the response crew for comment, and shared with senior management.

Municipalities are not currently required to submit incident reports to authorities under federal or provincial regulations. The key environmental authorities, however, would like to receive informational copies of the report for their own records. The Official in Charge should ensure that an incident report containing the appropriate information is assembled and distributed.


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Depending on the consequences of an incident, written reports should be sent to the following organizations within 30 days:

• Fisheries and Oceans Canada • Environment Canada • B.C. Ministry of Environment, Land and Parks

Municipal officials should also inform the general public of the major causes and consequences of any major incident through news releases to the local media.


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ORGANIZATION AND DATA COLLECTION

3.1 Environmental Protection Policy All municipalities within the GVRD possess policy statements on emergency preparedness, and many may have specific policies on environmental protection. The Water Operations Supervisor should identify and review these policies and suggest how they might be adapted to formally recognize the need to prevent and respond to the unintentional release of chlorinated water. This may involve revising existing policies, or adding a separate policy on chlorinated water. A policy statement outlines, for its employees and the general public, the municipality's commitment to environmental protection and the importance it places on emergency response. The policy should be signed by a senior municipal representative with responsibility for implementing the actions. A sample policy statement is offered in Table 3-1.

3.2 Emergency Planning Coordinator A single position should be responsible for coordinating the efforts needed to ensure preparedness: The Emergency Planning Coordinator. An important principle in emergency planning guides the selection of this person. The personnel with responsibility for managing the response effort should be the ones to prepare the plans and procedures. For water line breaks, organizational responsibilities and procedures are usually managed by the Water Operations Supervisor, although individual titles may vary. The Water Operations Supervisor, therefore, should perform the role of Emergency Planning Coordinator and be responsible for providing policy and technical advice to the municipal Emergency Planning Committee. The Emergency Planning Coordinator should be responsible for preparing and updating the Environmental Emergency Response Plan for Chlorinated Water. During a major emergency, the Coordinator serves as a management representative, developing appropriate response activities.


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Table 3-1. Sample Environmental Policy for Chlorinated Water

Sample Environmental Policy for Chlorinated Water The municipality of is committed to delivering domestic, commercial, and industrial potable water while achieving the highest standard in protecting the natural environment. Our employees will make every effort to ensure the safe distribution of chlorinated potable water throughout our service area. Facility managers will ensure the safety and protection of people, property, and the environment during water handling, storage, and distribution. To address these objectives, our municipality has set the following policies:

1. We will not knowingly release chlorinated water to the aquatic environment without neutralizing the chlorine.

2. We will respond as soon as possible to accidental breaks in our water systems and control releases of chlorinated water.

3. We will operate the system with vigilance to detect when changes in water flow rate or pressure signify a break and possible release.

4. We will educate all our staff on the potential impacts of chlorinated water on aquatic life

and train appropriate staff for response. 5. We will maintain our distribution system in good working order and upgrade where

necessary in order to prevent unforeseen ruptures.

This Environmental Emergency Response Plan is designed to ensure consistent implementation of these policies in dealing with releases of chlorinated water. The responsibility and authority to prepare and implement this plan rests with the Municipal Administrator, who will continually update this plan to meet changing requirements. Signature: Effective Date:


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3.3 Planning Committee Each municipality has an Emergency Planning Committee to address a list of threats to municipal interests. The Water Operations Supervisor should undertake annual presentations to the Municipal Emergency Planning Committee to ensure members are aware of the risks, prevention efforts, and emergency procedures for chlorinated water. The Water Operations Supervisor should also involve this committee in the planning process, perhaps by offering a presentation on the risks, legal requirements, prevention efforts and response procedures of the Operations department. Other key response departments are usually represented on this committee, so it offers important opportunities to coordinate response procedures, such as emergency notification.

3.4 Risk Assessment Every municipality has evaluated the risks associated with a wide range of natural and human-caused emergencies. The Water Operations Supervisor should ensure the municipal risk assessment is updated with specific information on the likelihood and consequences of a release of chlorinated water. At a minimum, the Water Operations Supervisor should undertake an assessment of the municipal water system. This involves determining what can go wrong, the potential effects, the likelihood of occurrence, the frequency of occurrence, and the probable locations. A municipality should consider the generic risk assessment information included in Appendix A. An assessment of risks associated with chlorinated water is helpful from two perspectives. First, knowing the potential threats is an essential first step. Secondly, knowing the details of loss events can help identify response equipment and resources, anticipate procedures, and coordinate strategies among several agencies. To assist with this assessment, each municipality will have been given the computerized Water Spill Response Planning System which offers a map view of environmental information for the municipality’s service area.


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This system provides rapid electronic map information on the following components:

• Colour Aerial Photograph Base (1:20,000) • Creeks / Streams • Fisheries Information • Critical Aquatic Features, such as Hatcheries • Water Mains • Storm Sewer Systems

3.5 Appropriate Laws and Regulations The Water Operations Supervisor should also identify the local, provincial, and federal laws that pertain to the release of chlorinated water into the environment. A legal review helps set the response planning parameters and scope of the effort. Municipal officials should consult with regulatory agencies to clarify requirements, expectations, and penalties. Appendix B offers a brief summary of federal and provincial legislation and regulations addressing chlorinated water. The Water Operations Supervisor should also clarify local by-laws that may affect emergency response decisions.

3.6 Roles and Responsibilities To prepare for response to the release of chlorinated water, each municipality should establish an integrated emergency response organization. The responsibilities of each of the key players during an environmental emergency are summarized in this section. Because of the variability in size and concern of leaks and breaks, however, not all actions will be expected on every incident. Figure 3-1 presents a proposed emergency management organizational structure for including chlorinated water within existing municipal plans. The remainder of this section lists the roles and responsibilities for the positions noted. In addition to department roles, the Water Operations Supervisor should address the responsibilities in other municipal departments. The dispatcher, for example, must know the steps to take upon receiving a report of water line leak or break. Likewise, the police and fire departments may play support roles in closing streets or warning residents of possible flooding from water releases. The sewer department should be notified if the discharge is into a sewer main.


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Municipal Emergency Planning Committee The municipal Emergency Planning Committee would rarely be involved in response to chlorinated water releases. There are some circumstances, however, where the Committee may be the appropriate body to coordinate municipal resources. A major earthquake, for example, would compel the Committee to mobilize the municipal Emergency Operations Centre, where they would wish to know the response efforts of the Water Operations Supervisor and the status of the water system. The Municipal Emergency Planning Committee undertakes the following responsibilities.

Before an Emergency

1. Identify opportunities to coordinate response efforts among departments, such as in training all dispatch staff in procedures for reporting water line leaks and breaks.

2. Oversee the assessment of risks related to the release of chlorinated water. The

assessment may serve the needs of other municipal departments, as well.

3. Confirm procedures developed by the Water Operations Supervisor and presented for consultation.

4. Revise procedures within the municipal Emergency Operations Centre (EOC) to

accommodate decisions unique to a major water spill and threat to environmental resources. Such procedures may employ the WSRS System.

During an Emergency

1. Oversee the coordination of response efforts by multiple departments through the

activation of the EOC.

2. Consider and authorize appropriate expenditures for unusual measures to protect the environment, where appropriate.

3. Contact neighbouring municipalities and organizations, as appropriate.

4. Provide a spokesperson for dealing with public relations and media enquiries.

After an Emergency

1. Direct an incident investigation of response efforts, costs, and overall consequences of


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major events.

2. Manage any claims of damage as a result of the spill. Water Operations Supervisor The Water Operations Supervisor should be authorized to undertake immediate and effective action during an incident involving chlorinated water. The Water Operations Supervisor should seek written authorization to act in this role and be prepared to share the authorization notice with anyone who may question, and thereby delay, effective action. Some municipalities divide their jurisdiction into areas, with an Area Manager having overall decision-making authority. The Water Operations Supervisor or designate should be responsible for performing the following functions:

Before an Emergency

1. Ensure authorities for action are in place through liaison with the municipal Emergency Planning Committee.

2. Purchase and distribute emergency response equipment appropriate to the control and

neutralization of chlorinated water.

3. Develop emergency response procedures, including 24-hour responsibility.

4. Authorize the training of Operations personnel in all aspects of emergency notification, response, and documentation.

5. Assemble risk information appropriate to the level of threat in various regions of the

municipality. Use this information to enhance prevention efforts and response capability.

During an Emergency

1. Assess the situation, if appropriate, activate the department emergency response plan, and inform appropriate personnel.

2. Assume responsibility for decisions regarding operational control of chlorinated water

releases.

3. Authorize the recall of off-duty staff to assist with emergency response efforts.


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4. Ensure all external agencies are notified immediately upon recognition of a threat to environmental resources.

5. In major emergencies, such as earthquake, liaise with the municipal Emergency Planning

Committee through the EOC.

6. Monitor the incident and record the rationale for all major decisions.

After an Emergency

1. Replenish any supplies, refurbish equipment, and restore materials expended in the course of response.

2. Debrief Operations staff and external agencies regarding possible improvements to

response procedures and prevention. Prepare an incident report.

3. Lead an investigation into the causes, consequences, and effectiveness of response of major incidents.

Dispatcher Emergency reporting of breaks must be routed through an agency with dispatch capability. While some municipalities use the police department for this function, we recommend that municipalities without their own police force use the fire dispatch on a designated non-emergency number. The dispatcher must be trained and able to assess the importance of the call and decide on notification steps. Key responsibilities of the Dispatcher include the following:

Before an Emergency

1. Confirm telephone numbers and other means of contact for key department personnel and environmental regulatory agencies.

2. Confirm 24-hour access to dispatch communications.

3. Complete training on the WSRP System. During an Emergency

1. Record all relevant information on an approved incident report form.


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2. Advise caller on how to collect assessment information.

3. Contact the Water Operations Supervisor or designated alternate, depending on the seriousness of the reported situation.

4. Contact outside organizations at the direction of the Water Operations Supervisor.

4. Relay information available through the WSRP System.

After an Emergency

1. Participate in post-incident reports and evaluations.

Operations Support Staff Most municipalities have likely established their own dedicated communication centre within the Water Operations office. These staff play important roles in response to chlorinated water releases, especially in providing information to decision-makers.

Before an Emergency

1. Become familiar with the computerized WSRP System to speed use during a major emergency.

2. Examine the decisions commonly faced in emergency response situations and identify the

information needs to facilitate these decisions.

During an Emergency

1. Activate the WSRP System for access to environmental information.

2. Provide information from other sources, upon the request of and in cooperation with the Water Operations Supervisor.

3. Coordinate information needs and assembly with other external resources and

government agencies.

After an Emergency

1. Participate in post-incident debriefings and investigations.


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Field Crews During working hours, initial response will likely be handled by members of a designated crew who are technically capable of assessing the accident scene and initiating an appropriate emergency response action. On weekends and in the evenings, some areas have roving patrols with responsibility for all areas. More senior decision-makers should be designated and available at all times. Once the nature of the break is assessed, the patrol has the option of contacting a designated standby with expertise in water line breaks, or the Water Operations Supervisor. All responders should have further contact lists.

Before an Emergency

1. Ensure training is adequate to the tasks that may be expected.

2. Ensure emergency equipment and supplies are available and ready for immediate use.

3. Participate in practice exercises to test emergency response procedures.

During an Emergency

1. Assess the situation upon arrival.

2. Secure the area in cooperation with local police or fire personnel.

3. Use personnel safety equipment at all times.

4. Undertake appropriate actions to control flow, contain the spill, neutralize chlorine, and monitor effects.

5. Communicate with the Water Operations Supervisor or designated person regularly.

6. Keep accurate records of major observations and response actions performed.

After an Emergency

1. Refurbish any equipment and supplies.

2. Prepare notes on major events.

3. Participate in post-incident investigations.


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3.7 Resources Controlling risks from chlorinated water depends on the availability of appropriate personnel, equipment, and information at critical times. Emergency planning efforts should identify resources needed to assess the importance of spills and to respond appropriately. The purpose of this step is to be ready to act as soon as possible. This will increase the likelihood of successful intervention. The Water Operations Supervisor bears the responsibility for ensuring the following equipment or equivalent is readily available for 24-hour access. Equipment and Supplies To respond to a typical leak or break in the water system, municipal crews should have the following equipment and supplies on hand:

1. Materials for spill containment, such as tarps, plywood, plastic sheets, and sewer covers. Access to a backhoe is essential..

2. Minimum of two 10 lb. bags of anhydrous sodium thiosulphate. 3. Four pre-made 10 lb. dechlorination bags (fibre mesh bags, approximately the size of

sandbags, containing anhydrous sodium thiosulphate). 4. Extra fibre mesh bags. 5. A stock of filled sandbags for constructing temporary berms. 6. Rope. 7. Field kit for measuring total residual chlorine. 8. Some method for measuring the weight or volume of dechlorination agent, such as a

balance. 9. Safety equipment

- Safety goggles - Rubber gloves - Particle masks - MSDS for sodium thiosulphate, chlorine test reagent

10. Record book or field notebook. 11. Phone numbers of the Official in Charge, Fisheries & Oceans Canada, Environment

Canada, the Ministry of Environment, Lands, and Parks, and the Provincial Emergency Program (PEP).

In addition, the following equipment would be helpful in recording the event and response:

12. Camera, film, and batteries. 13. Video camera, blank tapes, batteries, and recharging unit.


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Beyond simply having this equipment available, the municipal crews should prepare them for immediate transport. Crews should fill the sand bags and place them on a pallet. Personnel safety equipment should be stored in kit bags for convenient handling. Other Systems Mechanical field dechlorination equipment is available through commercial suppliers for emergency use. One such system, a sodium sulphite feeder by Eltech International Corporation, directs chlorinated water through a mixing chamber, where it contacts prepared sulphite tablets. Advance Chemicals Ltd. in Langley, BC supplies similar systems. As another example, the Kentucky - American Water Company assembled all the equipment needed to dechlorinate water onto an enclosed trailer unit. They found that their previous system of gathering the mixing barrels and other materials needed for sodium thiosulphate dechlorination required considerable time. To speed their response, they designed a self-contained unit with all the equipment necessary for safe, effective dechlorination. Components of their mobile dechlorination unit included the following:

• 1,000 L heavy duty polyethylene solution tank • Plastic chemical drum to store granular sodium thiosulphate • Electric generator and pump


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• Flow meter and other tools • Safety equipment, including portable eyewash unit • Joint sleeves and fabricated fittings to adapt to fire hydrants and other facilities

(Ref: James Singleton, Opflow, American Water Works Association, Vol. 19, No. 5, May, 1993) Assessment Resources In addition to the response equipment noted above, resources are required to assess reported spills. Evaluating the risk of a reported spill incident would require information available through water system maps, the risk assessment, and locations of sensitive environments available through the GVRD WSRP System.

3.8 Communication Communication is key to successful response to a release of chlorinated water. Timely, accurate, and clear information is vital for the safe and efficient handling of all emergencies. Communication Systems A means of notifying municipal officials of observed releases of treated water is vital to response. Notification methods should include telephone, radio, and pager systems, where a member of the public, municipal official, or other agency can report an incident to a central location. Because leaks may occur at any time, communication should anticipate a 24-hour notification system. Municipalities may also consider using answering services during off hours. Using an existing emergency response notification and dispatch system, such as that used for reporting the release of hazardous materials, may be the most efficient means of providing this service. The Water Operations Supervisor must detail the communication and reporting systems that are necessary to respond promptly. Contact Lists The Water Operations Supervisor should compile and maintain a list of telephone numbers of internal and external resources that can assist during an emergency. The list should include a brief description of these resources, a key contact name, an auxiliary contact, and means of activation. The contact list should include the environmental protection agencies itemized in Section 2.0.


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Risk Communication The public has an inherent right to be informed of environmental risks that might affect their enterprises and be warned and advised in case of an accidental release of chlorinated water. Adequate methods for informing those possibly affected should be developed to ensure rapid and efficient communication if an event occurs. Public Relations It is to the municipality's advantage to accurately and completely inform the public regularly with respect to the environmental hazards of chlorinated water and the municipal response. News media will report all available information, including references to rumours or second-hand information. Reporting the facts quickly will enhance community awareness, develop trust, and lead to improved citizen involvement. During a major spill, the municipality will wish to offer factual and credible information on the event and potential consequences. All information offered to media should be recorded and logged. A single spokesperson should be identified within the municipal Emergency Planning Committee. All Operations staff should be advised of the designated media liaison and instructed to refer interview requests to that person(s).


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PLAN ADMINISTRATION

4.1 Training All municipal employees with responsibility for managing risks from chlorinated water should receive training appropriate to their responsibilities under the plan. The amount and frequency of training will vary with the circumstances of the operation. The Water Operations Supervisor is responsible for ensuring all personnel with critical response roles are trained and experienced in the procedures they are expected to follow. Training includes opportunities to practice key procedures and refresher training, as appropriate. All members of the response team should be trained in the following basic elements.

• Knowledge about the plan and its provisions • Municipal policies for responding to emergencies • Use of the WSRP System and how to operate the program • How chlorinated water fits with other types of municipal emergencies • Response strategies and procedures • Use of response equipment • Roles and responsibilities

Specific topics should be covered in training of Field Crews, as follows.

• Location of existing water mains, contingency berms, bypass mains • Location and nature of nearby fish habitats • Procedures - Classroom discussion of checklist

- Assess situation - Contain spills, including the proper location of holding ponds - Dechlorinate, including use of field kits - Monitor, including looking for signs of environmental stress - Document observations and actions

• Personnel safety • Communications

Members of the field crews should be given opportunities to practice emergency response procedures. When possible, practice drills should include environmental scenarios prepared by the municipal


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Emergency Planning Committee and conducted with the appropriate response agencies. Initial training must be followed by periodic updates to maintain familiarity with all aspects of the plan. The Water Operations Supervisor should develop a system for tracking who receives formal training. In addition to training in direct response, the Water Operations Supervisor should update other existing training in WHMIS and Transportation of Dangerous Goods (TDG) to reflect the use of dechlorination and other chemicals used by field crews.

4.2 Testing Effective implementation of the emergency plan depends on the ability of municipal staff to discharge their responsibilities in coordination. The training of these individuals will be enhanced by having them apply their skills in a situation that simulates real events. The Water Operations Supervisor should be responsible for testing the various elements of the emergency plan to ensure procedures are current, comprehensive, and effective, at least annually. Testing usually is accomplished by one or more of the following means:

• Table-Top Exercises • Computer Exercises • Communications Exercises • Simulation Exercises

Supervisors may wish to consult the CSA Emergency Planning for Industry for guidance on exercise design and evaluation.

4.3 Updating Like all emergency plans, procedures for response to the unintentional release of chlorinated water need regular review and updating. The Water Operations Supervisor should be responsible for ensuring suggestions for improvement are collected and reviewed following every incident. In addition, all aspects of the plan must be reviewed and renewed at least annually. Dispatchers should contact external resources and verify contact procedures. All personnel included in the telephone contact list should be made aware that they are on the list and know what is expected of them. The Dispatcher should ensure that the list is up-to-date by calling them at least every six months. The entire plan should be reissued and redistributed to ensure that it is complete and up-to-date. Responsibility for maintaining the emergency plan should rest with the Water Operations Supervisor.


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4.4 Approval Approval mechanisms are already likely in place for other municipal emergency procedures, typically involving a review by the municipal Emergency Planning Committee. The Environmental Emergency Response Plan for Chlorinated Water should be reviewed and approved by the Water Operations Supervisor. In addition, to ensure it is compatible with other emergency plans, it should be approved by the Municipal Emergency Planning Coordinator.

4.5 Audit An audit of an emergency plan involves a formal review to determine the adequacy and completeness of the plan. It may consist of an internal review by members of the Operations Department, or an external review by the municipal Emergency Planning Committee. In some cases, a regulatory audit may be conducted by a government agency with regulatory duties for environmental protection. Regulatory officials will be looking for concrete evidence that a specific planning element has be adequately addressed. Elements that verify the written plan should be carefully documented in the following records:

• Response equipment inspection and maintenance • Training, noting subject and date by personnel • Prevention actions taken, listed by date • Incident reports and results of investigations


APPENDICES

A - RISK ASSESSMENT

B - LEGISLATION

C - DEFINITIONS


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APPENDIX A - RISK ASSESSMENT

A.1 Chlorine Concentrations Chlorine is acutely toxic to fish at a concentration of 0.02 mg/L, and less. With the GVWD primary chlorination system, potable water typically contains chlorine residuals of 0.5 to 1.1 mg/L, depending on the distance between the point of chlorination and the sample site. With rechlorination, the GVWD is aiming for a minimum of 0.2 mg/L in the far extremities of the municipal distribution system. This means more risk of environmental impact for municipalities. Table A-1 estimates the effects of the secondary disinfection on residual chlorine levels throughout the municipal distribution system. Chlorine residuals have always posed an environmental threat, even without secondary disinfection. Municipalities and other jurisdictions, however, may not be aware that the domestic water supply may cause damage and incur regulatory penalties. Section 36(3) of the federal Fisheries Act prohibits the deposit of a "deleterious substance" in any place where it may enter water frequented by fish. Chlorine is toxic to fish so it could be considered a deleterious substance. In the past, the GVWD and other municipalities within the region have been charged and found guilty of depositing a deleterious substance for accidental releases of chlorinated water. In other events, Fisheries & Oceans Canada officers laid charges and convictions were brought under the Fisheries Act when municipal water mains broke in 1989 and 1990. In both incidents, released chloramine-disinfected water drained to Fergus Creek and resulted in fish kills in the area. It should be noted that chloramine is more stable in the environment than chlorine.


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Table A-1. Chlorine Residuals in GVWD mains throughout the Transmission System, Pre- and Post-Rechlorination

(free chlorine residual in mg/L)

Municipality

Chlorination of Source

Water Only

With Re-Chlorination*

Burnaby

0.0 - 0.4

0.4 - 1.0

Coquitlam

0.3 - 0.5

0.5 - 1.0

Delta

0.0 - 0.2

0.2 - 1.0

Langley, City of

0.2 - 0.3

0.7 - 1.0

Langley, Township of

0.0 - 0.2

0.5 - 0.6

Maple Ridge

0.2 - 0.3

0.6 - 1.0

New Westminster

0.0 - 0.3

0.4 - 1.0

North Vancouver, City of

0.3 - 0.7

0.5 - 0.7

North Vancouver, District of

0.3 - 0.7

0.4 - 1.0

Pitt Meadows

0.3 - 0.4

0.7 - 1.0

Port Coquitlam

0.5 - 0.7

0.5 - 1.0

Port Moody

0.3 - 0.4

0.4 - 0.7

Richmond

0.0 - 0.3

0.5 - 1.0

Surrey

0.0 - 1.0

0.2 - 1.0

U.E.L.

0.2 - 0.3

0.6 - 0.7

Vancouver

0.2 - 0.6

0.4 - 1.0

West Vancouver

0.4 - 0.5

0.4 - 0.5

* Occasionally, these could be higher (up to 1.5 mg/L)for short durations during abnormal water quality conditions.


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A.2 Water Storage and Delivery Systems GVWD water is supplied from three source reservoirs. The water flows by gravity, except for certain pressure zones where it is pumped through more than 10 permanent pumping stations, and distributed through 500 km of supply mains to 18 Lower Mainland municipalities. Here are the major components of the system. Refer to the Environmental Impact Assessment (GVRD, 1993) for further details. GVWD Source Reservoirs (Water Supply Lakes) The water supply to the Lower Mainland municipalities originates from three watersheds in the North Shore mountains. The system consists of three major dams, the Cleveland Dam on the Capilano River, Seymour Falls Dam on the Seymour River, and Coquitlam Dam on the Coquitlam River. Three smaller dams are located at Burwell Lake, Palisade Lake, and Loch Lomand. At the present time (Fall, 1997), the GVWD’s treatment of the water supply consists of screening at the source inlets and primary chlorination at each of the three major reservoirs. Gaseous chlorine is injected into the source lines. Typical chlorine dosages range from 1.1 to 1.6 mg/L with ten-minute residuals of approximately 0.9 to 1.1 mg/L. Automatic backup systems have been installed at all three main reservoirs. If the chlorine residual drops to a preset low level, the backup system injects a liquid sodium hypochlorite solution into the supply main. GVWD Transmission Lines Both the Capilano and Seymour transmission lines extend southward from each reservoir, through the District of North Vancouver and under Burrard Inlet at the First Narrows and Second Narrows crossings, respectively. On the north side of Burrard Inlet, a 1,370 mm (54-inch) diameter intertie connects the two systems. South of Burrard Inlet, the system interties with the Coquitlam source near the City of New Westminster. Branched transmission mains form a looped, interconnected network. The GVRD transmission mains are predominantly constructed of welded steel, coated with coal tar enamel on both the interior and exterior surfaces. The structural integrity of the system is very good and GVWD transmission main failures rarely occur.


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GVWD Storage Reservoirs The GVWD manages 28 concrete water storage reservoirs in 20 locations throughout the region for meeting peak hour and fire flows. Storage volumes vary between 2.27 ML (500,000 Igal) and 139.8 ML (30,800,000 Igal). Municipal Storage Reservoirs There are 60 storage reservoirs in the municipalities, with capacities ranging from 0.17 ML (37,400 Igal) to 135 ML (30 million Igal). They operate on the same premise as the GVWD reservoirs. Currently, all tanks and reservoirs are constructed of concrete, though some tanks have been constructed of steel in the past. Depending on the size of the tanks or reservoirs, concrete columns may support the ceiling. Rechlorination Stations The Newton Station currently rechlorinates the GVWD water distribution system in Surrey. The City of Vancouver also has three rechlorination stations. Municipal Distribution Lines The Lower Mainland water main network comprises nearly 8,000 km, with about 7,500 km of municipal lines and 500 km managed by the GVWD. Water mains are a major potential source of accidental discharge. Municipalities purchase wholesale water from the GVWD. The municipal distribution network draws water from metered points on the GVWD transmission mains and line branches. Most municipal distribution networks comprise a variety of different piping materials. Downtown Vancouver and the older areas of New Westminster use predominantly cast iron, which was the common piping material during the early part of this century. Municipalities that developed in the 1950's and 1960's, such as Richmond, have a higher percentage of asbestos cement mains. Currently, ductile iron and PVC are the predominant pipe materials, with welded steel and concrete cylinder pipe being used for large diameter water mains. Customer Service Lines After transiting the GVWD transmission system and the municipality's distribution network, water passes through the customer's individual service connection and premises to the tap. Residential service lines are usually 19 mm in diameter. Chronic, low volume releases are more likely from runoff of treated water used for daily activities, such as lawn watering, car washing, and driveway flushing to the storm sewer system. Depending on the location, water delivered to residences may contain a chlorine residual at this time. Because the GVWD is embarking on a program of secondary disinfection, municipal


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managers should assume that all water being delivered to residences in the GVRD will contain some chlorine. At present, most member municipalities do not treat the water they receive, with the exception of the City of Vancouver, which rechlorinates some areas of the City.

A.3 Local Environment The GVWD service area contains significant fish and wildlife resources. The Fraser River is a central feature of the Greater Vancouver region and one of the most productive rivers in North America. The most important commercial fish species is salmon. On average, about 7 million salmon representing all five eastern Pacific species migrate through water bodies in the GVWD, with the Fraser River salmon run being the most important. Of these, more than 100,000 salmon spawn within the waters of the GVWD (Environmental Impact Assessment Stage 1 Report, 1992). Up to 800 million juvenile salmon migrate and/or rear in the Fraser River in an all-species peak year. In addition, the Fraser River Estuary contains wetlands of international significance. Estuary habitat provides feeding and resting areas for several million birds that migrate along the Pacific Flyway between South America and the Arctic Circle. Most Lower Mainland streams contain sensitive resources that could be affected by the discharge of water carrying chlorine residuals. Major rivers such as the Capilano, Seymour, Pitt, Coquitlam, Serpentine, Nicomekl, and Campbell and their tributaries support significant salmon spawning runs. Smaller streams throughout the North Shore and Fraser Valley support runs of lower magnitude but equal importance. High gradient streams, inaccessible to migratory fish, frequently sustain populations of resident cutthroat trout. Even streams that lack fish usually provide a source of fish food, such as insect larvae that drift downstream (EIA, Stage 1 Report, 1992).

A.4 Risks and Types of Events An emergency plan identifies the types of events that might occur to encourage early thoughts about an appropriate response. The following types of events are examples of unintentional releases.

Leaks. The GVWD annually attends and repaired dozens of leaks and breaks in the GVWD system. The majority of leaks are "pinholes" and occur on pipe varying in size from 300 mm up to 1200 mm diameter. The leaks are typically plugged and banded or plugged and welded. Pinhole leaks typically result in flows of 10 to 20 L/minute.

Breaks. Breaks in the water system usually release larger volumes of water, but occur less frequently.


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Types of events include:

• Failure of the pipe wall • Improperly sealed joints • Defective service valves • Corrosion holes

A number of factors may contribute to water main leaks and breaks, and the interrelationships among these factors may be complex. Some of these contributing factors are listed below:

• Pipe characteristics • Magnitude of loads and forces exerted on the main over time • Extent of internal and external corrosion • Construction or line maintenance activities • Soil liquefaction • Expansive soil • Frost penetrating ground movement • Groundwater table • Landslide • Pavement condition • Pressure changes • Road salting • Seismic events • Service leaks • Stray direct currents / lack of cathodic protection • Temperature change • Tidal intrusion

The chance of accidental release of chlorinated water varies with a number of contributing factors. The most common types of unintentional water releases occur with visually undetectable leaks, varying from less than 0.1 L/s to about 1.0 L/s. Because leaks of this size are usually undetectable, there is no attendance. Even newly constructed pipe is expected to leak at a very small rate. These negligible leaks present very low risk of impact on receiving waters because most of the water would infiltrate into the ground before reaching a water course. Leaks that are detectable flow at rates greater than 0.1 L/s. A pinhole leak on 300 mm up to 1200 mm diameter pipe could result in flow at a rate ranging from approximately 0.05 to 2.0 L/s. Recent water main leaks and repair records for the GVWD suggest that detectable leaks in the 500 km GVWD


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distribution system occur about 41 times per year, or 8 leaks per 100 km of distribution pipes. The majority of the leaks were pinhole types with estimated flow rates of less than 1.0 L/s. In one large incident, a 1020-mm diameter main split due to excessive loading from heavy equipment. This resulted in a loss of about 23 million L at a flow rate of about 2,200 L/min. Between 1989 and 1991, there were three water main leaks within the GVWD transmission pipelines that resulted in flows greater than 10 L/s. In October of 1992, the GVWD's 750 mm water main in South Surrey failed, discharging flows up to 750 L/s of chloraminated water. Dechlorination efforts resulted in no fish impacts. Leaks with a flow rate greater than 100 L/s are extremely rare. The risk of this type of leak is almost exclusively associated with the very large diameter pipes of the GVWD transmission mains. The GVWD system includes some very large utility transmission mains, up to 3,100 mm in diameter. A complete break in a 900 mm pipe, for example, would result in a flow rate between 100 and 1,000 L/s. The distribution system in each municipality consists mostly of small diameter pipes. Almost 94 percent of the pipe in the City of Vancouver, for example, is less than 300 mm in diameter. If the GVRD statistics can be used as an average case for the entire distribution system with a total pipe length of about 8,000 km, the total number of water main leaks throughout the service area is estimated at 640 times per year.


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APPENDIX B - LEGAL REVIEW The Water Operations Supervisor should ensure the current assessment of legal requirements for emergency prevention and response include environmental protection regulations. An overview of legal requirements should cover such topics as notifying environmental agencies, undertaking immediate efforts to halt environmental degradation, and the penalties for failure to act. Fish-bearing and sustaining resources are protected through a combination of federal, provincial, and local regulations.

B.1 Federal Legislation Federal Fisheries Act The federal Fisheries Act would apply when there is a deleterious deposit into a place where it may enter fish frequented waters. The Act is designed to protect fish and fish habitat for the purpose of protecting fisheries as a resource. According to the Act (Section 34(1)), fish habitat includes:

...spawning grounds and nursery, rearing, food supply and migration areas on which fish depend directly or indirectly in order to carry out their life processes.

A significant aspect of the Fisheries Act, dealing with the release of toxic substances, is applicable to the release of chlorinated water. Section 36(3) of the Act states

No person shall deposit or permit the deposit of a deleterious substance of any type in water frequented by fish or in any place under any conditions where the deleterious substance or any other deleterious substance that results from the deposit of the deleterious substance may enter any such water.

The definition of "deleterious substance" under the federal Fisheries Act is broad. For the purposes of the Act, it means

34 (1) (a) Any substance that, if added to any water, would degrade or alter or form part of a process of degradation or alteration of the quality of that water so that it is rendered or is likely to be rendered deleterious to fish or fish habitat or to the use by man of fish that frequent that water, or


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(b) Any water that contains a substance in such quantity or concentration, or that has been so treated, processed or changed, by heat or other means, from a natural state that it would, if added to any other water, degrade or alter or form part of a process of degradation or alteration of the quality of that water so that it is rendered or is likely to be rendered deleterious to fish or fish habitat or the use by man of fish that frequent that water...

In addition, the definition of "deposit" is broad and means any discharging, spraying, releasing, spilling, leaking, seeping, pouring, emitting, emptying, throwing, dumping or placing. Any person who contravenes Subsection 35 (1), 36(1), or 36(3) is guilty of:

40 (1) (a) An offence punishable on summary conviction and liable, for a first offence, to a fine not exceeding three hundred thousand dollars and, for any subsequent offence, to a fine not exceeding three hundred thousand dollars or to imprisonment for a term not exceeding six months, or to both; or

(b) An indictable offence and liable, for a first offence, to a fine not exceeding one million dollars and, for any subsequent offence, to a fine not exceeding one million dollars or to imprisonment for a term not exceeding three years, or to both.

Section 38 of the federal Fisheries Act places certain responsibilities on anyone who is responsible for a deleterious substance. Section 38(4) defines those who have responsibility as anyone who

(a) Owns the deleterious substance or has the charge, management, or control thereof, or

(b) Causes or contributes to the causation of the deposit of the danger thereof. Section 38(4) requires that, in the event of an accidental deposit of a deleterious substance to water frequented by fish, the responsible party report the occurrence to an inspector or other authority as prescribed by the regulation. However, current regulations are limited to reporting by the pulp and paper industry. While there is no legal requirement for reporting spills of chlorinated water at present, it is common and professional practice, and the policy of the GVRD to report spills of chlorinated water to Environment Canada. Under Section 38(5), every person described as having responsibility in paragraphs (a) and (b)

...shall, as soon as possible in the circumstances, take all reasonable measures consistent with safety and with the conservation of fish and fish habitat to prevent any occurrence referred to in subsection (4) or to counteract, mitigate or remedy any adverse effects that result or may reasonably be expected to result therefrom


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Section 38(6) gives an inspector the power to prescribe mitigative measures and require the person(s) in authority to undertake them. Any person who contravenes Section 38 by failing to report, failing to undertake reasonable measures to prevent deposit of a deleterious substance or to remediate, or fails to comply with the direction of an inspector

40 (3) (f) ...is guilty of an offence punishable on summary conviction and liable, for a first offence, to a fine not exceeding two hundred thousand dollars and, for any subsequent offence, to a fine not exceeding two hundred thousand dollars or to imprisonment for a term not exceeding six months, or to both.

Additional information on penalties can be found in Section 79 of the Fisheries Act. Environment Canada Guidelines The Canadian Council of Ministers of the Environment (CCME) (and the B.C. Ministry of Environment) have established guidelines for chlorine compounds (measured as total residual chlorine) in fresh water. For the protection of freshwater organisms, the CCME (1987)2 determined that the concentration of total residual chlorine in surface waters should not exceed 0.002 mg/L. The Environment Canada criterion of 0.002 mg/L is below the limit of detection of the measurement method for total residual chlorine, and thus is difficult to apply in a useful manner. Available data indicate that toxic effects on salmonid fish or fish food organisms in fresh water should be negligible or minimal if Environment Canada's criterion is not exceeded. Some studies suggest, however, that toxic effects might occur on certain sensitive species of freshwater invertebrates (e.g., Daphnia magna) at concentrations below 0.002 mg/L (Sprague and Drury, 1969; Arthur and Eaton, 1971). Further studies are required to confirm whether this is the case.

B.2 Provincial Criteria The government of British Columbia has established ambient water quality criteria for chlorine. The criteria have been developed based on the length of time of exposure and are defined in terms of Total Residual Chlorine (TRC) or (CPO). The TRC includes all forms of chlorine that are able to act as an oxidant.

2 It should be noted that these guidelines are subject to a review with a Draft of the new guidelines being

reviewed in November, 1997. Under the draft guidelines, the new guidelines for total residual chlorine for the protection of freshwater aquatic life may be as low as 0.4 ug/L and for marine aquatic life, 2.4 ug/L. These guidelines are still in the draft stages with no known final date.


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The B.C. Ministry of Environment has developed ambient water quality criteria for chlorine, as follows: For controlled intermittent exposures

The average total residual chlorine concentration should be time-related and should not exceed the numerical value (in �g/L) given by the formula [1074 (duration)-0.74], where duration is the uninterrupted exposure period in minutes.

The total duration of exposure in any consecutive 24-hour period should not exceed 2 hours.

The maximum concentration of total residual chlorine should not exceed 100 �g/L (0.1 mg/L) regardless of the exposure period.

For continuous exposure:

The average total residual chlorine concentration should not exceed 2 �g/L (0.002 mg/L). The averaging period should not be less than four days, nor more than thirty days. A minimum of five samples, equally spaced in time, should be used to calculate the average.

Although the BCE's freshwater criterion for continuous exposure has adopted the value specified by Environment Canada, the Provincial standard is less restrictive in that it is based on a five-sample average value, rather than a single maximum value. A release of chlorinated water that exceeds Environment Canada's standard may result in penalties, even if it meets the provincial value. The concentration required to produce a toxic effect decreases with increasing exposure time. The B. C. Ministry of Environment criteria for total residual chlorine should safely protect fish from impacts of free chlorine. Acceptable levels range from 0.1 mg/L total residual chlorine for exposure time less-than-or-equal-to 25 minutes to 0.002 mg/L for exposure periods of 4 days or longer. According to the B.C. criteria for controlled intermittent exposure of freshwater life, the maximum total residual chlorine (TRC) concentration should not exceed 0.1 mg/L, regardless of the exposure period. This maximum limit applies to an exposure of 25 minutes or less. Note that the values given here for exposures beyond two hours, while based on the BCE equation of the acute toxicity threshold, are somewhat inconsistent with the Provincial criteria for controlled intermittent exposure. Based on available literature, the B.C. water quality criteria for chlorine and freshwater organisms provide adequate protection of regional fisheries resources and other sensitive freshwater life. For the purpose of assessing spills of chlorinated water (which would not be regularly repeated events), it would be appropriate to use the B.C. equation for periods up to 96 hours.


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Some examples of criteria for duration of exposure are shown in Table B-1.

Table B-1. Approved and Working Criteria for Water Quality, B.C. Ministry of Environment, Lands and Parks (1995)

Duration of Exposure (Minutes)

Allowable TRC in

Freshwater mg/L

Allowable CPO1 in Marine and

Estuarine Waters mg/L

� 0.2

0.04

�25

0.1

30

0.087

0.005

90

0.038

0.003

>120

continuous criterion

0.002

0.003

1 Chlorine-produced oxidant

B.C. Environmental Management Act

The Environmental Management Act confers broad duties, powers and functions upon the Environment Minister in matters relating to the management, protection, and enhancement of the environment including water resources.

B.C. Waste Management Act

The Waste Management Act is designed to prohibit the introduction of waste in the environment in such a manner or quantity to cause pollution.

B.C. Water Act

The Water Act provides for the issuance of water and licences to divert and use or store water, or to undertake works in a stream or channel as provided in the licence.

B.C. Fisheries Act

The provincial Fisheries Act applies generally to the licensing of persons who fish or take fish or who assist a person who does take fish.


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APPENDIX C - DEFINITIONS Chlorine: Chlorine is a halogen element isolated as a heavier-than-air, greenish yellow gas. Chlorine is typically extracted from salt (NaCl) and used as a bleach, oxidizing agent, and disinfectant in water purification. Chlorine is the most common disinfectant in use in North America. As a powerful oxidant, it reacts with organics in the water to form chlorination byproducts. The pathways or mechanisms of disinfection are not fully understood. One theory holds that the DNA of the bacterial cell is "scrambled," the bacteria cannot reproduce, and the population dies. Another theory maintains that the nucleic material of the bacterial cell is oxidized and the cell dies. In any event, chlorination is effective. Chlorine forms long lasting residuals that continue to disinfect the distribution system. This is one of the main advantages of using chlorine as a disinfectant. Chlorine is used in two different forms: 1) Chlorine gas dispensed by gas chlorinators, and 2) Hypochlorite compounds that are mixed into solution and then injected into the water or wastewater being treated. Chlorine Residual: The amount of chlorine remaining in a system at the end of a specified contact time. The residual may be determined as free chlorine residual, combined chlorine residual, or total chlorine residual. Chlorine Dose: The amount of chlorine applied per unit of water or wastewater, expressed in ppm or mg/L. Free Chlorine Residual: The amount of chlorine available as hypochlorous acid and hypochlorite ions (and any dissolved chlorine gas) that is not chemically combined. These are the most effective forms of chlorine residual for providing strong disinfection. Combined Chlorine Residual: The combined residual existing as a chemical combination of chlorine and nitrogen-containing compounds. It is determined by measuring the total chlorine residual and the free chlorine residual, and then subtracting the free residual reading from the total residual reading. Dechlorination: The removal of excess chlorine residual to a specific level (usually zero). This is normally done to protect receiving water aquatic life. Detection Limit: This is the limit to which an apparatus can detect the potential contaminant of concern. Emergency Response Plan: A detailed program of action to minimize the effects of an abnormal event requiring prompt actions beyond normal procedures to protect human life, minimize injury, optimize loss control, and to reduce physical asset and environmental degradation.


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Hazard: A physical or social situation with a potential for human injury, damage to property, damage to the environment, or some combination of losses. mg/L: A unit of concentration used in the metric system. The weight of one milligram of a substance in one litre of solvent. ppm (parts per million): A unit used in measuring the concentration of a chemical in water. It is equivalent to one weight unit in one million weight units. For example, one pound of chlorine dissolved in one million pounds of water would be 1 ppm. The metric system uses mg/L or milligrams per litre as the approximate equivalent unit. Primary Disinfection: Primary disinfection using chlorine is used in the GVRD to disinfect the drinking water supply at the source prior to it entering the transmission system. Secondary Disinfection: Secondary disinfection is used in a distribution system where initial disinfection with free chlorine is insufficient to provide residual chlorine throughout the system. A free chlorine "boost" is applied to rechlorinate the system. Risk: The likelihood of a specified undesired event occurring within a specified period or in specific circumstances. It may include either a frequency (the number of specified events occurring within a unit of time) or a probability (the likelihood of a specified event following a prior event), depending on the circumstances. Total Chlorine Residual: The summation of free chlorine residual and combined chlorine residual.


REFERENCES

Norecol, Dames & Moore, Inc. (1992). Greater Vancouver Regional District Environmental Impact Assessment of Proposed Secondary Disinfection of Drinking Water Baseline (Stage I) Report.

Norecol, Dames & Moore, Inc. (1993). Greater Vancouver Regional District Environmental Impact Assessment of Proposed Secondary Disinfection of Drinking Water Stage II Report.

Norecol, Dames & Moore, Inc. (1993). Greater Vancouver Regional District Environmental Impact Assessment of Proposed Secondary Disinfection of Drinking Water Stage III Report.

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