Emergency Response Plan

An emergency response plan must be developed and implemented as outlined in paragraph (q)(2) of
29 CFR 1910.120.

Sewerage treatment plants may use applicable sections of their Toxic Catastrophe Prevention Act
(TCPA) Risk Management Plan (RMP) as part of their 29 CFR 1910.120 (q)(2) ERP to avoid
duplication. However, RMP's approved by the New Jersey Department of Environmental Protection
(DEP) may or may not meet the minimum requirements of 29 CFR 1910.120. The TCPA emergency
response plan cannot be considered a substitute for the ERP unless it contains detailed provisions for
the protection of emergency response employees in each of the 11 required elements. Some
chemicals, such as sodium hypochlodte (NaOCI), do not require TCPA registration. However, these
chemicals are listed as hazardous chemicals and do require an ERP under 29 CFR 1910.120.

For guidance in developing these procedures listed below, obtain a copy of the "Occupational Safety
and Health Guidance Manual for Hazardous Waste Site Activities" from the U.S. Department of
Health and Human Services National Institute for Occupational Safety and Health (USDHHS
NIOSH) (Publication No. 85-115). This document can be obtained from:

Superintendent of Documents
U.S. Government Printing Office
Washington, D.C. 20402

The PEOSH Program has developed an information bulletin on the requirements of 29 CFR
1910.120 and a model ERP that can be used by STP's. This bulletin and model ERP can be obtained
from the New Jersey Department of Health and Senior Services' PEOSH Program by calling (609)
984-1863.

The Emergency Response Plan must contain at at minimum 11 elements describing

emergency responder health and safety procedures as follows:
1. Pre-emergency planning and coordination with outside parties,
2. Personnel roles, lines of authority, training and communication,
3. Emergency recognition and prevention,
4. Safe distances and places of refuge,
5. Site security and control,
6. Evacuation routes and procedures,
7. Decontamination,
8. Emergency medical treatment and first aid,
9. Emegency alerting and response procedures,
10. Critique of response and follow-up and
11. Personal protective equipment (PPE) and emergency equipment.

Training for Emergency Responders Training for emergency responders shall be based on the
duties and functions of the employee. The required levels of training are:

l First Responder Awareness Level

Employees who are likely to witness a release of a hazardous material and are only authorized
to initiate appropriate action (such as notifying the proper authorities) are required to receive
sufficient training or objectively demonstrate competency at this level. There is no minimum
 number of hours specified in the standard for this level of training.

l First Responder Operations Level

Employees who respond by taking defensive measures only, such as diking, are required to
receive sufficient training or objectively demonstrate competency at this level. These
employees shall not handle or come into contact with the hazardous material at any time
during the response. A minimum of eight hours of training is required for this level.

l Hazardous Materials Technician or Hazardous Materials Specialist Level

Employees who respond to potential or actual releases of hazardous materials in an effort to

terminate the release are required to receive a minimum of 24 hours of training.

l On Scene Incident Commander Level

Employees who will assume control of an incident scene beyond the awareness level are
required to receive a minimum of 24 hours of training that includes the operations level.

The required training can be obtained through the use of private consultants or in-house
training programs provided that all of the minimum elements are adequately covered in each
level of training. Required training may also be arranged through the New Jersey State Police
Office of Emergency Management, which administers free training programs for NJ public
employee emergency responders involved in hazardous materials incidents. The Office of
Emergency Management may be contacted at (609) 538-6067 for further information.

All training levels require annual retraining or demonstrated competency.

Medical Surveillance

To evaluate the potential for impairment due to overexposure members of Hazardous Materials
Teams responsible for handling leaking containers and other methods to terminate the release of a
hazardous material must receive baseline physical examinations and yearly exams, unless the
attending physician believes a longer interval (not greater than biannually) is appropriate. These
examinations are to be provided at no cost to employees and at a reasonable time and place.
Employees who exhibit signs orsymptoms which may have resulted from exposure to hazardous
substances during the course of an emergency incident, either immediately or subsequently, shall be
provided with medical consultation.

Chemical Protective Clothing

Employees shall be provided with chemical resistant clothing and proper respiratory protection. If
there is a potential inhalation hazard, a positive pressure Self-Contained Breathing Apparatus
(SCBA) shall be used until air monitoring determines that a decreased level of respiratory protection
will not result in hazardous exposures.

29 CFR 1910.132 - Personal Protective Equipment

This standard requires that employees be provided with personal protective equipment (PPE) for
protection from hazardous or harmful substances or conditions. This includes gloves, face shields,
goggles, aprons or coveralls and other protective shields and barriers.

Areas where PPE may be needed include aeration and settling tanks where splashing may occur and
lime and polymer rooms where dusty operations may cause employee exposures to chemicals.

29 CFR 1910.134 - Respiratory Protection

This standard requires that when employees are issued respirators, written standard operating
procedures governing the selection and use of respirators must be provided by the employer.

The written program shall include provisions for employee training on the proper use of respirators,
a program for proper storage. cleaning, disinfecting, and inspection of respirators, and evaluation of
the effectiveness of the respiratory protection program. The program should also include a medical
monitoring program to determine if employees are physically able to wear a respirator.

Areas in STP's where respiratory protection may be needed include chlorine rooms, confined spaces,
and areas where employees may be exposed to hydrogen sulfide (H2S) or methane (CH4).

29 CFR 1910.151 - Medical Services and First Aid

One requirement of this standard is that an approved eyewash capable of providing at least fifteen
minutes of continual flushing and/or an approved drench shower must be provided within 100 feet or
ten seconds travel time in areas in which corrosive materials are used. The unit(s) should be located
as close to the hazard as possible and on the same level. The maximum time required to reach the
unit(s) should be determined by the potential effect of the chemical. For a strong acid or strong
caustic,the unit(s) should be immediately adjacent to or within 10 feet of the hazard. It is
recommended that the consulting physician be contacted for advice on the proper distance. The
American National Standards Institute (ANSI) standard for emergency eyewash and shower
equipment should be used as a guide for proper installation. This document is available from the
American National Standards Institute, Inc., publication Z358.1-1990. ANSI, 11 West 42nd Street,
13th Floor, New York, NY 10018, (212) 642-4900.

Some areas in STP's that require approved eyewashes and/or drench showers include chlorine rooms,
garages with parts cleaners, and areas where lime is added to the sludge. If the Material Safety Data
Sheet (MSDS), supplied with each substance, or the New Jersey Hazardous Substance Fact Sheet
states that 15 minutes of eye flushing is required for first aid in the event of eye contact an approved
eyewash is necessary in the area where the substance is used.

Frequent inspections should be conducted to ensure that all eyewashes and drench showers are
working, maintained in a clean condition, and are not blocked in a manner that will inhibit free
access.

29 CFR 1910.1450 - Occupational Exposure to Hazardous Chemicals in

Laboratories

This standard applies to laboratories in which chemicals are not produced, but are used as reagents in
experiments and tests. Employee protection is provided for by standard operating procedures for
training, test protocols, and the development and implementation of a written Chemical Hygiene
Plan that delineates procedures for all laboratory operations.