Commissioner's directive 318-3: Environmental emergency plan (EEP)

PRIMARY GOALS

To eliminate, reduce and/or mitigate environmental impacts in the event of hazardous substance releases at Correctional Service of Canada's institutions.

To ensure preparedness to react in the event of accidental spills of hazardous materials in accordance with pollution prevention rules and obligations.

To establish formal response procedures that will minimize damage which may occur as a results of accidental spills of hazardous substances.

For each institution, to develop, adapt and integrate an Environmental Emergency Plan to respond to accidental spills of hazardous materials, to provide specific training, and to hold drills, so as to ensure preventive and responsible environmental protection management.

To prepare staff and inmates for quick and effective responses to equipment failure, accidents, sabotage, or other incidents that could cause environmental damage (impacts), more specifically:

• adjacent soil contamination and devaluation of the land;
• contamination of nearby watercourses;
• release of atmospheric pollutants (particularly when fire occurs subsequent to spills);
• contamination of the aquifer (underground water) and consequently of drinking water when there are artesian wells on the affected site;
• introduction of toxic substances to the food chain via contamination of ecosystems and/or vegetable and animal species;
• destruction of natural habitat, animals and/or material assets; and
• losses, injuries or assaults on the quality of human life.

• Correctional Service of Canada Commissioner's Directive 318 - Environmental Programs.
• Sustainable Development Strategy (SDS) of the Correctional Service of Canada.
• Canadian Environmental Protection Act, 1999.
• Fisheries Act, 1985.
• Transportation of Dangerous Goods Act, 1992.
• Hazardous Products Act, 1985.

For the purpose of these Environmental Guidelines:

The Institutional Head, his or her assistants and the Corcan Operations Managers are accountable to ensure compliance with these Environmental Guidelines.

The Chief, Plant Maintenance (CPM) will normally be the person responsible for implementing and monitoring these Environmental Guidelines, so that Environmental Emergency Plan activities may be managed, reviewed and maintained from a central point in the institution.

All Correctional Service of Canada's sites are subject to these Environmental Guidelines.

ENVIRONMENTAL EMERGENCY PLAN (EEP)

1. The Institutional Head must formally assign responsibility for developing and maintaining a state of preparedness for staff and inmates to implement an Environmental Emergency Plan (EEP) for the institution [refer to Annex A].
2. The persons assigned to the institution's EEP must put in place mechanisms and procedures that will allow for preventive and responsible management of emergency responses to environmental incidents (e.g. accidental spills of hazardous materials) in conformity with local safety regulations.
3. In order to be able to contend with potential spills of hazardous materials, the CPM will plan for response measures. In general, preparation for an EEP comprises three main stages:
   1. response plan;
   2. related training; and
   3. drills (simulations).
4. The CPM will identify and describe the incident scenarios that are to be addressed in the institution's EEP. The incident scenarios that are deemed to be material should then be screened for duplication in the institution's other emergency response plans.
5. For each incident scenario addressed in the institution's EEP, the CPM will coordinate the development of a response plan which:
   1. describes each incident scenario;
   2. identifies and describes the tasks that must be carried out to respond to the incident effectively;
   3. specifies which officers (and inmates) must carry out each defined task;
   4. identifies any special equipment or supplies to be used, where they are kept, and how they are accessed;
   5. prescribes how contaminated supplies and equipment are to be cleaned up or disposed of;
   6. communicates requirements for reporting the incident as identified in these Guidelines;
   7. updates the EEP annually before March 31st. (It is suggested that the annual updating of EEPs be done concurrently with the annual updating of WHMIS sheets.)
6. The Institutional Head or his or her assistant will test the institution's environmental emergency response capability by carrying out annual simulation exercises. This requirement is waived in a particular year if the institution has responded to a real incident during that year.

1. Appropriate on-site records must be kept that will show the ongoing results on the institutional EEP.
2. An institutional register of hazardous material spill prevention actions taken (e.g. development of a response plan, contacts and agreements established in this regard, training sessions, simulation exercises, reports on actual incidents, etc.) must be kept up to date at all times.
3. All documents required in these Environmental Guidelines (EEP, annual reports, training records, simulation log, etc.) must be kept on site for at least five years following the date of issue.

4. If any leak or spill of hazardous materials occurs, the CPM or a member of his or her team must document for future reference - with supporting photographs or video - the relevant circumstances surrounding the event, and the steps taken. When the situation is over, an appropriate incident report should be drafted within 48 hours [refer to Annex G].
5. Once completed, the incident report signed by local authorities (CPM, AWMS or Institutional Head) must be sent to the Regional Environmental Officer and to the Manager of Environmental Programs at National Headquarters whose mandate is, as appropriate, to inform and/or forward the incident report to Environment Canada.

6. Depending on the nature of the incident, the Environmental Emergency Plan must also take into consideration regulations, directives, codes of practice, guides and other federal and provincial documents which require or recommend that immediate incident notifications or reports be forwarded to the government agencies concerned. Thus, for accidental spills:
   1. pursuant to the Canadian Environmental Protection Act (CEPA), it is mandatory to notify Environment Canada of any accidental spill of a toxic substance identified in Schedule 1 of the CEPA (PCBs, ODSs, asbestos, mercury, etc.);
   2. pursuant to the Fisheries Act, it is mandatory to notify Fisheries and Oceans Canada of any spill of contaminants into waters where fish live, and the incident must also be reported to Environment Canada, which administers the relevant sections of the Fisheries Act;
   3. pursuant to the Transportation of Dangerous Goods Act, 1992, Transport Canada must be notified of a spill which occurs while a contaminant is being transported; and
   4. the Environment Ministry of the province concerned should be notified of the accidental release of a contaminant.

1. The CPM will develop a plan for training all staff (and if appropriate, inmates) who are assigned emergency response duties in the EEP, and for keeping their training up to date. The purpose of training is to give response personnel members the knowledge and skills they need to carry out their roles and responsibilities safely and effectively, in accordance with the procedures stipulated in the EEP. Therefore, the CPM will:
   1. give or arrange for the required training so that response personnel members are trained as required in terms of risk related to hazardous materials present in their unit; and
   2. ensure that the frequency of training or refresher sessions is established in accordance with circumstances and requirements.
2. The CPM will ensure that annual simulations/drills are carried out to test and improve the institution's Environmental Emergency Plan [refer to Annex H].
3. The CPM will keep a log (in the local register set up for that purpose) of the status of all EEP training, simulations and updating events (including pertinent recommendations).

4. Environment Canada infonet site - Environmental Emergencies: http://www.ec.gc.ca/ee-ue/main/main_e.cfm.
5. Environment Canada infonet site - Environmental Emergencies Contacts: http://www.ec.gc.ca/ee-ue/contact/contact_e.cfm.
6. Environment Canada infonet site for "Environmental Emergency (E2) Plans": http://www.ec.gc.ca/ee-ue/plans/e2qa_e.cfm.
7. Environment Canada's Implementation Guidelines on "Environmental Emergency (E2) Plans": http://www.ec.gc.ca/ee-ue/plans/e2guide_e.pdf.
8. Transport Canada CANUTEC infonet site (home page): http://www.tc.gc.ca/canutec/en/menu.htm.
9. Transport Canada CANUTEC infonet site - Emergency Response Guidebook 2000 (ERGO): http://www.tc.gc.ca/canutec/en/guide/guide.htm. (Through this link, the PC version of the ERGO 2.5 can be downloaded.)
10. Fisheries and Oceans Canada infonet site (home page): http://www.dfo-mpo.gc.ca/home-accueil_e.htm.
11. Fisheries and Oceans Canada/Canadian Coast Guard infonet site - Environmental Response: http://www.ccg-gcc.gc.ca/rser-ssie/er-ie/main_e.htm.
12. Practical Handbook for Emergency Operations – Response to Oil Spills – First Alert to Final Cleanup (Environment Canada, 1995). Environment Canada infonet site (The Green Lane home page): http://www.ec.ca/envhome.
13. Emergency Planning for Industry, Major Industrial Accidents, Canadian Standards Association, CAN/CSA-Z731-95. CSA internet site: http://www.csa.ca.

Assistant Commissioner,
Corporate Services

Original signed by:
Louise Saint-Laurent

ANNEX A - Major Hazardous Materials Commonly Used in CSC Institutions and EEP Preparation

Preparation of an Environmental Emergency Plan (EEP)

While equipment failures, accidents, or sabotage can happen in any organization, the possibility of malicious events leading to environmental damage (although these events usually occur on a small scale) may be higher in a CSC institution than in many other settings. The CPM should first attempt to identify all of the types of incidents that could occur at the institution that would cause significant environmental damage. These should then be screened for materiality, as preparations to respond to an incident scenario are time consuming and expensive. The CPM should judge whether an incident scenario is material based on whether the likelihood that it would occur is "not insignificant", whether if it did occur it would be a big or small event, and whether the big or small event would cause much environmental damage.

• Other contingency plans at an institution deal with security incidents, fires, WHMIS and other health risks, power failures, etc. that may be due to equipment failure, accidents, sabotage, riots, etc. These plans may already include measures to reduce the likelihood of an incident scenario or minimize its environmental impacts. For example, it may be possible to augment the institution's fire response plans or WHMIS documents to deal with some environmental contingencies.
• The standard operating procedures for some apparatus include measures for responding to unusual conditions. For example, the sewage treatment plant operator may already have contingency plans for dealing with chemical shocks in or blockages of sewage influent.
• Environmental Guidelines identify most of the environmentally hazardous substances in an institution and include measures to prevent or contain spills or leaks of these substances in most ordinary circumstances. EEPs normally deal with only a few of these substances.
• On the other hand, it may become evident that the institution's other emergency response plans, standard operating procedures, or the Environmental Guidelines do not cover some types of incidents. For example, the water plant operator may require a contingency plan for dealing with water that has a low disinfectant level, or that has become contaminated, or that has been poisoned.

ANNEX B - Principal Locations in CSC Institutions Where There Is a Risk of Accidental Spills

• one marked 75-gallon polyethylene drum with a screw-on lid

• 1 perforated roll, 19" x 144" x 3/8"
• 25 pads, 17" x 19" x 3/8"
• 3 absorbent pillows, 21" x 16" x 6"
• one 21-litre bag (selective loose sorbent for hydrocarbons)
• 8 socks, 3" x 48"
• 1 drain cover, 36" x 36"
• 1 tube of epoxy filler
• 2 pairs of Solvex gloves
• 2 pairs of Tyvek disposable coveralls
• 2 recovery bags, 40" x 60" x 6 mm
• 1 recovery container

ENVIRONMENT CANADA -
Regional Environmental Emergency Coordinators

Atlantic
(902) 426-2576

Quebec
(514) 283-2345

Ontario
(416) 739-5908

Prairie and Northern
(780) 951-8753

Pacific and Yukon
(604) 666-6496

For questions, comments or suggestions concerning environmental emergencies, contact Environment Canada by e-mail at: environmental.emergencies@ec.gc.ca.

FISHERIES AND OCEANS CANADA -
Canadian Coast Guard Regional Contacts for Reporting Environmental Incidents and Cleaning

UpBC and Yukon
1-800-889-8852

Alberta, Saskatchewan, Manitoba, Ontario, NWT, Arctic
1-800-265-0237

Quebec
1-800-463-4393

Maritime
1-800-565-1633

Newfoundland
1-800-563-2444

For general questions on the Canadian Coast Guard programs and services (e.g. marine spills response contacts), send an e-mail message to: info@dfo-mpo.gc.ca.

The Emergency Response Officer or any employee assigned responsibility for dealing with the spill or leak must act as quickly as possible to locate the source and, if possible, to neutralize the spread of the liquid product. The following procedures are suggested:

• be careful - do not take any action if there is imminent danger (if toxic fumes or gases are present, or if there is any risk of explosion, wait for the response team to arrive);
• if appropriate, approach the site carefully, with the wind at your back;
• close taps or valves;
• make temporary repairs to containers and temporarily seal all cracks;
• reposition the container (e.g. drum) so that the perforation causing the leak is at the top; and
• recover spilled liquids by transferring them to an empty container.

To ensure effective response at strategic locations, clearly identify the potential pathways of substances spilled into the environment. Consider the following points:

• spread on ground or floor surface;
• infiltration into the ground or floor; and
• penetration into the sewer system (drains, access shafts, manholes, ditches, cable ducts, etc.).

Then take the necessary measures to limit soil or water borne damage spread.

To contain such spills, dig pits or trenches, build retaining dikes around the contaminant and use sorbents [see following table]. Use of a sorbent-containing emergency kit is prescribed. It is important to isolate all water sources (sewer outlets, watercourses, etc.) with sorbents.

When contaminants are spilled into water or reach a flat body of water, the most appropriate response will take into account the dimensions and rate of water flow and the morphology of the banks. Possible responses (avoiding directing liquid spills toward sewer systems) are:

• construction of retaining dikes with ducts;
• use of natural topography or a ditch;
• excavation of a well or trench;
• floating barriers made of sorbents and/or absorbent socks;
• booms (logs and planks, drums, etc.); and
• plywood sheets installed at culverts.

Once the contaminant has been contained, recovery operations must be carried out as quickly as possible. This means picking up, cleaning and temporarily storing the spilled substance and any sorbents used. It is important that any products spilled be removed from ground and water, to reduce the risk of contaminant migration. When conditions allow, it is always preferable to pump a spilled substance directly, without using sorbents. A number of specialist pumping firms are accredited to respond in this type of situation, and contacting them to recover the contaminant and contaminated materials is recommended.

Following completion of the emergency response, a number of other tasks must be carried out:

• clean-up and restoration of contaminated areas;
• disposal of contaminated soil and water and residual hazardous waste; and
• preparation of a report on the spill [see Annex G].

Simulations make it possible to prepare to respond to an incident by practicing procedures stipulated in the Environmental Emergency Plan. The purposes of simulations are:

1. to improve effectiveness and check the implementation of knowledge acquired in response training;
2. to validate environmental emergency plans and other significant response reference works;
3. to put into practice and to improve response techniques and procedures; and
4. to improve the design and execution of future exercises.

Simulations may be carried out internally or with external resources. Internal exercises permit the evaluation of risks, roles and the existing response capability. Exercises in cooperation with external resources make it possible to plan and conduct a similation with pooled resources and efforts. These exercises allow external participants to become familiar with the site and the factors which may be involved in an accident and to check whether external response teams are able to respond adequately.

Simulations can be of three types:

1. Operational exercises are aimed more specifically at groups which carry out practical tasks. Generally, they are based on prescribed standards and operating procedures. The purpose of these exercises is to improve first response capability.
2. Management exercises are intended for response team members, not operational employees. They are designed and carried out by those who wish to improve their degree of response preparedness.
3. Combined exercises are designed to evaluate the response team's capability to manage a number of crucial response functions simultaneously.