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Suggested Citation:"Chapter 13 - Special Considerations." National Academies of Sciences, Engineering, and Medicine. 2014. A Debris Management Handbook for State and Local DOTs and Departments of Public Works. Washington, DC: The National Academies Press. doi: 10.17226/22239.
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Suggested Citation:"Chapter 13 - Special Considerations." National Academies of Sciences, Engineering, and Medicine. 2014. A Debris Management Handbook for State and Local DOTs and Departments of Public Works. Washington, DC: The National Academies Press. doi: 10.17226/22239.
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Suggested Citation:"Chapter 13 - Special Considerations." National Academies of Sciences, Engineering, and Medicine. 2014. A Debris Management Handbook for State and Local DOTs and Departments of Public Works. Washington, DC: The National Academies Press. doi: 10.17226/22239.
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Suggested Citation:"Chapter 13 - Special Considerations." National Academies of Sciences, Engineering, and Medicine. 2014. A Debris Management Handbook for State and Local DOTs and Departments of Public Works. Washington, DC: The National Academies Press. doi: 10.17226/22239.
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Suggested Citation:"Chapter 13 - Special Considerations." National Academies of Sciences, Engineering, and Medicine. 2014. A Debris Management Handbook for State and Local DOTs and Departments of Public Works. Washington, DC: The National Academies Press. doi: 10.17226/22239.
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Suggested Citation:"Chapter 13 - Special Considerations." National Academies of Sciences, Engineering, and Medicine. 2014. A Debris Management Handbook for State and Local DOTs and Departments of Public Works. Washington, DC: The National Academies Press. doi: 10.17226/22239.
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Suggested Citation:"Chapter 13 - Special Considerations." National Academies of Sciences, Engineering, and Medicine. 2014. A Debris Management Handbook for State and Local DOTs and Departments of Public Works. Washington, DC: The National Academies Press. doi: 10.17226/22239.
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Suggested Citation:"Chapter 13 - Special Considerations." National Academies of Sciences, Engineering, and Medicine. 2014. A Debris Management Handbook for State and Local DOTs and Departments of Public Works. Washington, DC: The National Academies Press. doi: 10.17226/22239.
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Suggested Citation:"Chapter 13 - Special Considerations." National Academies of Sciences, Engineering, and Medicine. 2014. A Debris Management Handbook for State and Local DOTs and Departments of Public Works. Washington, DC: The National Academies Press. doi: 10.17226/22239.
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Suggested Citation:"Chapter 13 - Special Considerations." National Academies of Sciences, Engineering, and Medicine. 2014. A Debris Management Handbook for State and Local DOTs and Departments of Public Works. Washington, DC: The National Academies Press. doi: 10.17226/22239.
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Suggested Citation:"Chapter 13 - Special Considerations." National Academies of Sciences, Engineering, and Medicine. 2014. A Debris Management Handbook for State and Local DOTs and Departments of Public Works. Washington, DC: The National Academies Press. doi: 10.17226/22239.
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Suggested Citation:"Chapter 13 - Special Considerations." National Academies of Sciences, Engineering, and Medicine. 2014. A Debris Management Handbook for State and Local DOTs and Departments of Public Works. Washington, DC: The National Academies Press. doi: 10.17226/22239.
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Suggested Citation:"Chapter 13 - Special Considerations." National Academies of Sciences, Engineering, and Medicine. 2014. A Debris Management Handbook for State and Local DOTs and Departments of Public Works. Washington, DC: The National Academies Press. doi: 10.17226/22239.
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Suggested Citation:"Chapter 13 - Special Considerations." National Academies of Sciences, Engineering, and Medicine. 2014. A Debris Management Handbook for State and Local DOTs and Departments of Public Works. Washington, DC: The National Academies Press. doi: 10.17226/22239.
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Suggested Citation:"Chapter 13 - Special Considerations." National Academies of Sciences, Engineering, and Medicine. 2014. A Debris Management Handbook for State and Local DOTs and Departments of Public Works. Washington, DC: The National Academies Press. doi: 10.17226/22239.
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Suggested Citation:"Chapter 13 - Special Considerations." National Academies of Sciences, Engineering, and Medicine. 2014. A Debris Management Handbook for State and Local DOTs and Departments of Public Works. Washington, DC: The National Academies Press. doi: 10.17226/22239.
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100 Synopsis of Issues The term “special considerations” describes issues other than program eligibility that could affect the scope of work and funding for a debris management project. Environmental compliance, including regulatory policies, permitting, ecological considerations, and quarantine restrictions, is of special concern. Historic preservation may be an issue in many areas. Additionally, valuables, personal property, animal remains, and human remains must be treated properly when part of a disaster. Finally, debris in and around a crime scene must be moved only after approval by law enforcement officials. Target Audience • Debris managers, • Local officials, • Environmental officials, • Debris supervisors, • Landfill owners/operators, • Debris monitors, • Solid waste department, and • Debris removal contractors. Special Considerations Definition The circumstances surrounding a particular debris-generating event could impact how the debris management process is undertaken. Debris management plans should consider these possibilities and establish a framework for addressing them should they arise. Special consider- ations such as environmental compliance, historic preservation, personal property recovery, and environmental justice are encountered with some frequency. Some other events might require the debris management team and local officials to address topics such as animal remains, human remains, and crime scene evidence. Environmental Compliance Why: Environmental compliance can include regulatory, ecological, and/or quarantine issues. Many laws and executive orders mandate compliance with environmental regulations governing topics such as pollution and contamination, ecosystems, and land use. Table 13.1 includes the most common environmental laws and executive orders that could potentially impact debris management operations. C H A P T E R 1 3 Special Considerations

Special Considerations 101 Legislaon Impact on Debris Operaons Agency Authority Resource Conservaon and Recovery Act • Requires safe disposal of waste materials in properly permied landfills. • Encourages recycling of some materials. • Hazardous waste must be properly handled and disposed of in accordance with the requirements of the Act (e.g., properly permied landfill). State, EPA Clean Air Act Must comply with the requirements of the Act for permi­ng, reducon, and disposal of debris, including: • Burning debris. • Appliances containing chlorofluorocarbons. • Switches and fluorescent tubes containing mercury. • Asbestos- and lead-containing materials. State, EPA Endangered Species Act (ESA) • Idenfy endangered species in geographic area of impact - Habitats. - Breeding seasons. • Obtain programmac agreements as needed to accomplish debris work. • Do not remove, disturb, or otherwise harm protected habitat areas. • Do not place debris management or disposal sites in protected habitat areas. U.S. Fish and Wildlife Service (USFWS) Naonal Marine Fisheries Service (NMFS) Fish and Wildlife Coordinaon Act Debris removal from waterways that could impact fish and wildlife should be coordinated with USFWS. USFWS Clean Water Act (CWA) • Obtain permits for discharging dredged materials or fill into federal waters. • Prohibits use of wetlands for USACE DMSs. • Coordinate with USACE on how to accomplish debris removal from streams. Naonal Environmental Policy Act (NEPA) Debris acvies are generally statutorily exempt from NEPA requirements. FEMA (for Stafford Act responsibilies) Naonal Historic Preservaon Act (NHPA) Coordinate debris removal or demolion acvies impacng any historic property listed in or eligible for lisng in the Naonal Register of Historic Places with the state or Tribal Historic Preservaon Office. State or Tribal Historic Preservaon Officer, Advisory Council on Historic Preservaon Table 13.1. Summary of laws and executive orders pertaining to debris management. (continued on next page)

102 A Debris Management Handbook for State and Local DOTs and Departments of Public Works Legislaon Impact on Debris Operaons Agency Authority Coastal Zone Management Act (CZMA) Debris removal from coastal zones must be done in accordance with the state’s coastal zone management plan. State Coastal Barrier Resources Act (CBRA) Debris removal in Coastal Barrier Resources Systems to eliminate an immediate threat to lives, public health and safety, and improved property should be completed in consultaon with the USFWS. USFWS Farmland Protecon Act Use of farmland for a DMS likely will not comply with the requirements of the Act; verify with state NRCS before using. NRCS Execuve Order 11988: Floodplain Management DMSs and disposal sites cannot be located in a floodplain. FEMA Execuve Order 11990: Wetlands Management DMSs and disposal sites cannot be located in a wetland. FEMA Execuve Order 12898: Environmental Jusce Minimize disproporonately high effects of debris operaons on neighborhoods and communies with minority or low-income populaons (e.g., consider during DMS selecon). Mulple (Table compiled based on informaon contained in FEMA 325, Debris Management Guide) (25) Table 13.1. (Continued). Compliance with these laws during debris management operations is important not only from a legal standpoint, but also from a financial standpoint if reimbursement will be sought from federal agency grant programs. Federal agencies must comply with federal laws, and this requirement extends to providing federal funds to complete an activity. A federal agency must document that all applicable laws are being followed to be able to provide funds for disaster- related work. A sample environmental compliance checklist can be found in Appendix M. Example (37) After the devastating fires that occurred in September and October of 2011 in Bastrop County, TX, burned trees near power lines were cut down and placed alongside the road. Fire victims along these routes placed their debris in the right-of-way for eventual removal. Between the time the debris was placed in the right-of-way and the time it was removed, the endangered Houston toad took residence in the piles. Because FEMA, its Grantees, and Subgrantees must comply with the requirements of the Endangered Species Act, the Houston toad was required to be protected during debris removal activities. A team of Houston toad experts monitored the activities of debris removal and public utility crews to determine if the toad was present in their work areas. When toads were found, the experts coordinated with USFWS to safely handle and relocate the toad. Where: Environmental compliance issues arise based on where debris is found after a disaster as well as during removal, segregation, processing, and disposal operations. Debris that occurs in environmentally sensitive areas such as waterways, protected species habitats, and contaminated sites have to be removed in accordance with the federal, state, and local laws that apply to the particular site (see Figure 13.1). Debris removal operations likely need to be coordinated with the state and/or federal agency that has oversight of the law governing how certain activities should be accomplished.

Special Considerations 103 Environmental considerations also arise at debris removal and demolition sites in buildings where asbestos and/or lead-based paint might be present. Lead-based paint could be encountered in buildings constructed before 1978, and asbestos-containing materials (ACMs) are still used in some buildings. Appropriate personal protective measures should be taken by people handling lead-based paint and ACMs, and these materials should be properly treated and discarded in accordance with governing regulations. If DMSs will be used to facilitate debris management operations, these sites must be selected to comply with governing regulations. Additional discussions about site selection are included in Chapter 9. The sites should be permitted by the appropriate local and/or state authority. The site operations and closure procedures must comply with the permit and applicable laws, ordinances, and other authorities. Properly processed debris must be disposed of in accordance with governing requirements. Disposal requirements for different types of regulated debris are discussed in Chapter 11. Disposal sites must be properly permitted; disposal of debris such as chipped or shredded vegetative debris through uses such as mulch must be performed in coordination with state environmental agencies. When: Activities associated with performing life-saving measures immediately after the disaster has occurred are likely exempt from environmental regulations. Once life-saving measures are complete, debris removal and disposal operations must comply with relevant federal, state, and local requirements. Some potential environmental concerns can be identified and appropriate solutions can be addressed during development of the debris management plan. For example, site selection can be planned to comply with environmental justice concerns as well as floodplain man- agement requirements. Other potential environmental issues might be identified in the process of completing preliminary damage assessments and during segregation activities. As these concerns are identified, they should be brought to the attention of the debris manager so they can be properly and expeditiously addressed. Who: Many of the people directly involved in debris management operations should be aware of governing environmental regulations as well as the potential issues in their communities that might need to be addressed. These people include but are not limited to those outlined in Table 13.2. How: Debris management operations must comply with all local, state, and federal laws, ordinances, and other requirements that pertain to the types of solid waste generated as disaster Figure 13.1. Located near a body of water and in a wetlands, this DMS does not meet environmental criteria for site selection. (Source: FEMA)

104 A Debris Management Handbook for State and Local DOTs and Departments of Public Works debris. Debris managers, supervisors, and contractors are encouraged to consult with their state environmental agency regarding requirements for handling, transport, and disposal of disaster debris, particularly regulated debris such as hazardous waste. When DMSs are identified for sorting and/or processing debris prior to disposal, some steps that are recommended to ensure compliance with environmental regulations include: • Use GIS or obtain maps to identify areas such as wetlands, open water, and floodplains. Include aerial imagery of these sites. • Check local experts for information on elevation of groundwater tables to minimize the potential of contaminating groundwater. • Obtain and overlay maps of habitats for endangered/protected species onto the water/ wetlands maps. Table 13.2. Individuals involved in debris management operations and their roles. Individual or Agency Role Debris Manager Coordinate with appropriate agencies to ensure debris opera ons meet local, state, and federal regula ons. Communicate with contractors on requirements. Debris Removal Contractors Comply with local, state, and federal requirements for debris removal and disposal opera ons. Coordinate with debris manager, other agencies as appropriate. Debris Monitors Observe debris opera ons and raise concerns regarding non-compliance with local, state, and federal regula ons to the debris manager. Local Floodplain Administrator Iden fy local floodplains. Coordinate with debris manager on site selec on to ensure compliance with floodplain management. Ensure dredging opera ons comply with floodplain management requirements. State Department of Environmental Quality Issue permits. Ensure compliance with environmental requirements. State Department of Conserva on/Natural Resources Advise on debris disposal and recycling op ons. Advise on agricultural and other land use as a DMS. State Na onal Flood Insurance Program (NFIP) Coordinator Advise on dredging, site selec on to ensure floodplain management requirements are met. EPA Establish requirements governing the safe removal and disposal of disaster debris. Coordinate with USCG to remove oily and other hazardous debris from coastal zones. Coordinate with USACE on removal of CBRN contaminated debris. USFWS Advise on debris removal from waterways that could impact fish and wildlife. USACE Provide technical advice for debris opera ons. Coordinate with EPA on removal of CBRN contaminated debris. U.S. Coast Guard Provide technical assistance for contaminated debris in coastal zones. Coordinate with EPA to remove hazardous materials (e.g., oil) from coastal zones.

Special Considerations 105 • Comply with local, state, and federal requirements for locating DMSs in relation to sensitive areas (e.g., should not be located within certain distances of these areas). • Consider demographics and traffic studies near potential sites to ensure compliance with applicable regulations and executive orders such as environmental justice. • Obtain required permits (e.g., burning, ash disposal). • Complete baseline environmental sampling (e.g., water, soil, air) of DMSs prior to setting up the site. • Complete ongoing sampling as required by ordinances, regulations, and laws. • Monitor to ensure that hazardous and other regulated wastes are segregated, properly han- dled, and properly disposed. Ensure chain of custody is kept. A sample chain of custody form can be found in Appendix L. • Complete final environmental sampling after all debris operations are complete and cleanup has been accomplished. Compare results of post-operations sampling to baseline sampling to ensure the site has been returned to normal (or as close as possible to meet requirements). Historic Preservation Why: Historic preservation compliance is mandated by Section 106 of the NHPA, which was enacted into law in 1966 and last amended in 2006. It is intended to preserve historic and archaeological sites in the U.S. While historic preservation occurs at the local, state, tribal, and federal levels, the Act directs the federal government to provide leadership in preserving, restoring, and maintaining the nation’s historic and cultural resources. In so doing, federal agencies that disburse funds for disaster-related work through federal grant programs must ensure that applicable laws such as the NHPA are followed. What: Debris removal from potentially historic or archaeologically significant sites, as well as removal of demolition debris from historic properties, must comply with historic preserva- tion requirements. An exception will likely be made for life-saving emergency response work, but permanent debris removal might require coordination with the State Historic Preservation Office (SHPO) or Tribal Historic Preservation Office (THPO). Demolition and/or disposal of material from a known or potential historic structure, facility, or site should not be started without notifying the SHPO or THPO and receiving approval, and could require development of a written plan of action for debris operations. Known historic and archaeological sites should not be used for debris storage. Where: Historic preservation requirements should be followed for any property with the potential to have historic or archaeological significance. Some sites have already been identified and included on the National Register of Historic Places and the list of National Historic Landmarks. SHPOs and THPOs maintain lists of sites included on the registers for their states. The NHPA states that buildings must be at least 50 years old to be considered potentially historic. Debris personnel should confirm that properties 50 years old or older are not historically significant prior to removing debris from these sites. When: Requirements for historic preservation compliance are likely to be waived during life-saving operations, but after the rescue phase is complete, historic preservation compli- ance is required by law. Prior to removing debris from public property, sites with known disaster debris should be evaluated against the National Register of Historic Places. Some communities or states have GIS layers with the historic properties coded on them; this can be a useful tool for quickly identifying potential sites requiring compliance with NHPA requirements. Other debris-containing locations with the potential for meeting the definitions of historic or culturally significant sites should also be evaluated to determine if compliance with NHPA is required.

106 A Debris Management Handbook for State and Local DOTs and Departments of Public Works Who: The debris manager has primary responsibility for ensuring that debris operations per- sonnel and debris contractors comply with the NHPA. The debris manager should consult with the SHPO or THPO on currently listed and identified eligible properties in their communities, as well as sites identified by field personnel during debris management work. How: Sites with the potential for being historically or culturally significant can be identified by conferring with local historic preservation societies, tax records, and local officials regarding sites of known historic/archaeological significance, as well as by checking the National Register of Historic Places. As historic or culturally significant sites containing disaster-generated debris are identified, the debris manager should confer with the SHPO/THPO to develop a plan for removal of debris from these sites. Valuables/Personal Property Why: During a disaster, personal property becomes mixed in with other disaster-generated debris. Some personal property could have monetary or sentimental value. For these reasons, property owners are often anxious to recover their personal belongings and valuables after a disaster. Recovery of personal property with monetary value is also important for insurance purposes, as insurance companies need documentation of what has been recovered and what is lost to be able to process claims. What: Personal property can include a wide variety of belongings. Some items, such as vehicles, vessels, expensive jewelry, artwork, precious metals, and collectibles, may be insured and their recovery or loss must be documented and reported to insurers. Some items could be potentially dangerous, such as firearms, and should be handled by appropriately trained people. Other items such as photographs and family heirlooms have sentimental value to the owners and are irreplaceable. Where: While most personal property is likely to be found on residential or commercial property, it could be found anywhere in or near the disaster zone. Wind and water can carry items long distances before depositing them, so personal property might be found anywhere from feet to miles away from points of origin. When: Personal property is found before as well as during debris operations. Once local officials have determined a disaster area is safe for entry, residents and business owners may be allowed to return during a specified time period before the onset of debris removal operations so that they can search through the debris to find their personal belongings and valuables. Once they have reclaimed the items that they want, debris removal operations in these areas begin according to the debris management plan, and additional sorting by debris removal personnel to find personal property is not likely to occur. However, because debris can be carried far away from its points of origin, some personal property and valuables might be found during debris removal from public property. In cases of marine debris removal, property owners will not be able to remove much of the debris from the water themselves and will have to rely on marine debris removal operations to recover their property. The process for returning these items to their owners is likely to vary according to jurisdiction, but in general the items should be documented with photographs, date and time they are found, and GPS coordinates of the location where they are found. They then should be tracked through chain of custody forms, and secured until they are turned over to the appropriate local or state authorities for further processing. Who: If private citizens are permitted back into the disaster area to search for belongings and begin the recovery process, they are likely to find many of their valuables and keepsakes before removing debris from their property for disposal. Workers who are involved in search and rescue

Special Considerations 107 or debris removal and disposal operations may encounter personal property or valuables on public property or even private property if they have authorized entry. Personnel working for departments of public works, solid waste, transportation, and parks and recreation, as well as their contractors, are the most likely individuals to find and recover personal property during debris operations. These individuals should be trained in the proper procedures for catalog- ing and preserving these items, maintaining chain of custody, and turning the items over to the appropriate authorities for further processing. Coordination with law enforcement officials could also be required when dangerous or illegal items are found. Law enforcement or other designated agencies coordinate with insurance companies on the items recovered during debris operations. How: Local debris management plans should have a section that addresses how personal property and valuables are handled and processed during debris operations, including the estab- lishment of a central location (or locations) where such items are taken, what proof is required for pickup, and other details. Local debris management plans should also address the process of how residents return to the site. This process should describe how property owners can find out when they can return, and what is required for them to enter the area if it is cordoned off, such as a picture identification showing an address in the area. Depending on the nature of the disaster, if the times of entry to the area by residents and business owners are restricted, those times should be clearly communicated. If entering onto private property, contact the property owner first to obtain right-of-entry and to give the property owner an opportunity to indicate the presence of valuables or sentimental items that might remain on-site (38). As debris operations are ongoing, items that are potentially dangerous or “unusually valuable” such as firearms, coins, safes, or jewelry may be found. The debris personnel who find the items should start the chain of custody process, which could involve collecting, tagging, and photo- graphing each item. Items collected at a central location for safe storage until they can be turned over to the appropriate authorities may be logged into a database for additional tracking and documentation purposes. The appropriate local or state authorities should be notified so that the items can be transferred as quickly as possible. If recovered items need to be stored for a period of time before they are turned over to authorities, they should be kept in a locked safe or room with restricted access in a facility that is locked and has on-site security 24 hours per day, seven days per week. Titled property such as vehicles and vessels, if authorized for removal, should be taken to a secure storage location managed by the local government. Animal Carcasses Why: Animals can also be disaster victims. The death of animals due to disasters can pose logistical issues as well as health-related concerns for the affected communities, and so must be handled effectively and efficiently to assure the general public that the appropriate measures are being taken to safeguard against additional problems such as health risks. Previous disasters, such as Hurricane Floyd in 1999, resulted in the deaths of over 100,000 hogs and 1 million chickens and turkeys that quickly posed public health risks for disease as well as contaminated floodwaters and drinking water supplies (39) (see Figures 13.2 and 13.3). What: The types of animals that live and work in our communities are numerous and diverse. While the species can vary widely, animals can be loosely grouped by type (40). • Pets/companion animals are those in a generally tame condition. • Livestock/agricultural animals are often considered to be domestic and generally are considered to be farm animals.

108 A Debris Management Handbook for State and Local DOTs and Departments of Public Works • Exotic or zoo animals are generally considered to be wild animals. • Research animals could be domestic or wild animals, depending on the type of research being conducted. Rats and mice are the most commonly used animals for these purposes. Animal carcasses generated as a result of disaster can pose some significant concerns. Disasters that result in a large volume of carcasses will require significant space for storage until they can be properly processed and/or discarded, depending on methods deemed acceptable by the state agriculture department. Some animals could be carrying diseases or their carcasses could become breeding grounds for disease, which could pose a public health threat if not addressed quickly. Where: Animals carcasses could be found in a number of different places after a disaster. Pets and companion animals that were not able to be rescued could be found in or near residential areas, veterinary clinics, kennels, and at breeding facilities. Domestic farm animals could be found on or near farms, ranches, or in concentrated feeding facilities. Animals used for research are most Figure 13.2. Removal of dead hogs, Hurricane Floyd, 1999. (Source: FEMA) Figure 13.3. Disposal of dead hogs, Hurricane Floyd, 1999. (Source: FEMA)

Special Considerations 109 likely to be found on or near university campuses, private companies, nonprofit laboratories, government laboratories, or at other medical or health research facilities. When: Animal carcass removal should begin as soon as possible after a disaster to avoid creat- ing a health hazard. Removal and disposal should be accomplished in accordance with the local and/or state debris removal plan and in coordination with the appropriate state agencies such as Health and Agriculture. State agencies have recommendations for the appropriate time limits associated with different disposal methods; it is recommended that the appropriate state agency be contacted to verify disposal options and timeframes. Who: Many local and state plans require farms and other locations where animals are concen- trated to have a disposal plan prepared in advance of an event occurring. These plans should be coordinated with local emergency management officials and meet local and state requirements for animal carcass disposal. Farm and ranch owners are expected to handle the animal carcasses on their property after a disaster occurs. Similarly, pet owners generally are responsible for appro- priately disposing of their animals’ remains in accordance with local and state ordinances within 24 hours of receiving notice of the death (41). When removal is required by public agencies, removal and disposal is likely to be done by debris removal contractors and personnel from the department of public works or solid waste. Removal and disposal operations should be coordinated with the department of health and also animal control as appropriate. If animal carcasses must be transported off-site to another location for processing and disposal, the DOT might need to issue permits, and escorts from local law enforce- ment officials might be required. Sample requirements for disposal of large quantities of animal carcasses can be found in Appendix N and requirements for disposal of small quantities of animal carcasses can be found in Appendix O. Depending on the magnitude and location of the disaster, state resources might also be involved in animal carcass removal and disposal (see Table 13.3). How: Removal and disposal of animal carcasses resulting from disasters should be done in accordance with local and state regulations; local and state animal control, health, and agriculture departments can provide technical guidance and assistance. Because this is a specialized type of State Agency Role in Animal Carcass Removal and Disposal Department of Transportaon Assists with planning for animal transport. Issues transportaon permits. Coordinates with debris manager and PIO on public informaon. Department of Environmental Quality Provides technical support for removal and disposal. Issues permits for burning. Advises on landfill perming and usage. Department of Health Advises on disease control, worker health, and safety. Department of Agriculture/Veterinarian Might hold preposioned contracts for removal and disposal that could be acvated. Maintains list of haulers. Might have access to incinerators or maintains a list of incinerators. Department of Natural Resources/Soil and Water Conservaon Board Provides technical support for removal and disposal. Advises on burial, composng, ash disposal. Table 13.3. State agencies that might be involved in carcass removal (42) (43).

110 A Debris Management Handbook for State and Local DOTs and Departments of Public Works debris removal, staff that will be doing this type of work must be trained in the proper methods of collection, loading, transport, and disposal. The work can be both physically and emotionally exhausting; personnel should be rotated frequently (e.g., every few days) to other responsibili- ties to help prevent burnout. Workers should wear appropriate personal protective equipment (PPE), including tyvek suits, boots, and synthetic impermeable gloves. Safety glasses might also be appropriate. Removal operations involve moving the carcasses from their deposition locations to disposal sites or storage sites if immediate disposal is not available. Removal could require the use of different types of equipment typically available from departments of public works or trans- portation. Small animals can be moved by skid steers or bucket loaders, but larger animals may require the use of heavy equipment for removal. Equipment that might be needed to remove and transport animal carcasses after disaster include: • Skid steer loaders with attachments; • Front-end loaders; • Dump trucks; • Roll-off containers; • Cranes; • Chains, hooks, shovels; • Plastic sheeting (6-mil); • Poly bags with zipper; • Absorbent materials (e.g., sawdust, wood shavings, hay, straw); • PPE; • Duct tape to seal PPE; and • Communications equipment. If storage is required prior to disposal, store in cold areas (e.g., bury in snow piles if available) or place on plastic sheeting and cover with 3 feet of soil (44). Loading animal carcasses for transport requires that special processes be followed. Short- distance transport can be accomplished in lined and covered municipally-owned vehicles, but long distance hauls should be done in lined roll-off containers, lined and covered dump trucks, or other lined and covered “tippable” vehicles. Loading the vehicles used for transport must be done carefully, following a process similar to this one used by Franklin County, MA (44): • Seal off roll-off containers and dump trucks around the gate. • Double-line the container or truck bed with 6-mil plastic sheeting or polyethylene (poly) bags, leaving sufficient material at the sides to seal the top after loading is complete. • Load the container with 1-foot thick layer of absorbent material. • Handling the carcasses as little as possible, carefully load them into the container. Avoid tear- ing the liner or puncturing the carcass bodies. • Leave sufficient space to accommodate the expansion of carcasses; 1 to 2 feet of space is recommended. • After loading, cover carcasses with plastic sheeting attached to the sides and top of the con- tainer to prevent leaking, or zip the poly bag. Trucks that have been properly loaded should transport the carcasses by following a pre- established route. An escort from law enforcement agencies to the disposal sites might be needed and should be coordinated with the appropriate agencies. Acceptable disposal methods will vary based on the types and quantities of carcasses requiring disposal and should be coordinated with the appropriate local and state agencies, such as Health and Agriculture. The disposal area should be isolated from public areas, away from water sources, underground wells, and environmentally sensitive areas. Some disposal options that might be acceptable are shown in Table 13.4.

Special Considerations 111 Human Remains This is a difficult subject that the researcher have tried to treat with respect, while still convey- ing the nature of the work that could be required. Why: Loss of human life can result from natural disasters. The public expects that human remains will be recovered as quickly as possible to allow the friends and relatives of the victims to follow their burial traditions. Human remains that are not quickly recovered also could pose a health and safety risk to the community. What: Human bodies and body parts could be recovered as a result of any type of disaster. As the human remains are recovered, bodies should be placed in plastic body bags. If these are not available, plastic sheets, bed sheets, or other similar available material can be used. Body parts should be placed in small, portable ice chests prior to transport. Hurricanes and floods also can cause buried coffins to surface and float, and could dislodge human remains from their coffins. Where: The remains of victims of the disaster could be found under other debris, in buildings, in vehicles, etc., within or near the geographic area impacted by the disaster. Coffins and other human remains carried away by floodwaters could be deposited several miles from their points of origin. Method Descripon Rendering The easiest way to dispose of carcasses, especially those of farm animals. Rendering is a process whereby the carcass is cooked at high temperatures and converted to animal feed or ferlizer. Commercial companies perform this service and might, for a fee, pick up the animals. This method can be used if normal transportaon methods and ulies are funconal and the rendering company has sufficient trucks and personnel to handle the volume. Burning Can be done outside or by using commercial incinerators. Many animal hospitals, humane sociees, and diagnosc laboratories have incinerators, given that prior agreements are in place. When burning carcasses outside, it is important to let appropriate governmental officials know ahead of me to assure compliance with laws and ordinances. (May be a me limit for doing this.) Burial Can be done only where local ordinances and the terrain permit. The locaon selected should be approved in advance by the appropriate environmental government agency. Burial might only be permied at certain locaons. Arrangements might also have to be made for heavy equipment to move animals and dig the graves. A good resource for these supplies is the state transportaon department and Naonal Guard. The USDA APHIS “Foot and Mouth Disease Emergency Disease Guidelines” and “Hog Cholera Emergency Disease Guidelines” can be consulted for procedures for preparing the burial site. Composng Used to dispose of large numbers of poultry carcasses. Composng is the mixing by volume of 1 part carcass to 2 parts lier and 1 part straw in alternate layers in a boxed, enclosed area. The method can also be used for larger animals. Whereas poultry can be placed whole in layers, larger animals need to be cut or ground into smaller parts first. The composng is accomplished by the bacteria in the lier and takes about two weeks to complete. The completed compost pile is odorless and can be used for ferlizer. Fermentaon Carcasses are mixed with fermentable sugar in a metal container. Bacteria from the digesve tract of the carcasses ferment the material. The finished product can then be used for animal feed. Table 13.4. Animal carcasses disposal options (45).

112 A Debris Management Handbook for State and Local DOTs and Departments of Public Works When: Human remains will most likely be encountered during search and rescue and recovery operations after a disaster has occurred. While it is the objective of every recovery mission to find human remains as quickly as possible, the extent and nature of the disaster could result in some human remains being found weeks or even months into the recovery process. Who: During search and rescue operations, fire department and emergency services person- nel could request public works and transportation departments to identify potential facilities to serve as temporary morgues and also provide heavy equipment and operators to assist with operations by removing large and heavy debris. The local health department can advise on the use of PPE by these personnel during rescue and recovery operations. While on site, equipment operators may need to coordinate with structural engineers who are evaluating the integrity of structurally unsound or collapsed buildings so that building debris is removed as safely as possible to prevent further shifts in the structures. The operators might also need to coordinate with law enforcement personnel that have canine units on site. If human remains are found during search and rescue or recovery operations, the medical examiner will be notified to take possession. As search and rescue efforts transition to recovery operations, debris removal personnel, including contractors if they are used, could find human remains during debris removal operations. Such individuals should be trained in what to do if this occurs. If local capabilities to support this work are overwhelmed, the State National Guard might be able to provide personnel and equipment to support local efforts. The State Department of General Services might also be able to provide needed resources such as facilities, materials, and equip- ment necessary to support operations. If federal agencies are involved in the response efforts, the U.S. Public Health Service’s Disaster Mortuary Operational Response Team (DMORT) teams might be available to provide technical assistance with recovery efforts, including providing temporary morgue facilities if the impacted jurisdiction cannot identify appropriate facilities. The Department of Homeland Security’s Urban Search and Rescue Response System and the Department of Defense also have resources that can assist with recovering and processing human remains and also with handling potentially contaminated human remains. How: The local emergency operations plan should contain information on how the removal and handling of human remains will be accomplished in the ESF #8 section or in the mass fatality plan. Any work performed related to demolition or debris removal where human remains could be or are found should be done in support of and in close coordination with search and rescue/recovery operations and the local medical examiner’s or coroner’s office. Debris management workers should be trained in what their role could be during recovery of human remains after a disaster. They also should be trained in the proper methods used to protect against potential contact with bodily fluids as well as other hazards present at the removal sites. For example, the minimum recommended level of protection is heavy-duty gloves and boots, and workers should use water and soap to clean up after handling human remains. Personnel doing this work should be rotated to other jobs frequently to reduce the psychological toll that is associated with these responsibilities. When human remains are found by debris management personnel, the appropriate authorities should be notified to ensure that the proper protocols are followed during removal. Often the location where the body is found is marked in some way such as by flagging or spray paint (46). Debris management personnel might be requested to assist the marking process and also with transport of human remains after they have been processed in the field. Personnel who will be assisting with transport should be trained in chain of custody practices to convey human remains from point of origin to point of identification/storage. The transportation process is likely to require the use of enclosed vehicles or tractor trailers; refrigerated vehicles are preferred but might not be available. Transport vehicles should be secured near the recovery site until ready to depart. Some jurisdictions might require a police escort from recovery site to identification

Special Considerations 113 and storage site (46). Otherwise, transport should be convoy-style with no stops made along the way using a predetermined travel route coordinated with local law officials (47). Once the identification/storage location is reached, chain of custody will be turned over to the coroner or other death management personnel. In the event that coffins and associated human remains are dislodged from their interment locations as a result of severe flooding, efforts should be made to recover the coffins as quickly as possible and place them in a secure location. If coffins can be recovered by boat crews before floodwaters recede, the coffins can be tied to trees or other relatively stable/anchored objects so they can be retrieved quickly and brought to a designated location for evaluation by the coroner. At the impacted cemetery, exposed remains should be covered and left untouched until the medical examiner or other official is available to assist with searching for, recovering, and identi- fying the remains. Public works and transportation departments might be requested to provide personnel and equipment to assist with lifting and storing headstones until they can be re-set. The perimeter of the affected cemetery should be secured, and an official or other designated person might be posted at the entrance to the cemetery to answer the questions of loved ones and let them know if their relatives were impacted by the flood. Crime Scene Evidence General: The debris management plan should include a general process for debris removal operations at a crime scene. It is important that both law enforcement and debris operations maintain close coordination during cleanup. Key evidence can be ruled inadmissible if not handled properly. For example, a rear axle from the explosive-laden truck was found over a block from the Alfred P. Murrah Building following the 1995 Oklahoma City bombing. The part number was used to track the manufacturer and owner (rental company) of the truck, and eventually led to the bomber. Fortunately, no one had touched or moved the axle before tagging, photographing, and removal by law enforcement personnel. Why: While the majority of disasters that have occurred in the U.S. historically have been natural disasters, not all fall into this category. Manmade disasters also occur; and while many have been found to be accidental, several have been intentional. Because the origin of a man- made disaster might not immediately be determined as accidental, some manmade disasters are initially treated as potential crime scenes until evidence of a crime is ruled out. Under these circumstances, it is crucial to preserve evidence, including debris, for investigation of possible crimes. For example, the West, TX, fertilizer plant explosion was initially assumed to be an accident. Law enforcement officials subsequently considered the possibility that the incident might have been intentional and instituted a criminal investigation that included “stacking any piece of debris that might be useful on blue tarps and hauling away the rest” (48). What: Crime evidence is mixed in among all of the debris that results from an incident. The types of objects that are considered evidence depend on the nature of the incident and are deter- mined by law enforcement officials. In addition to evidence that a crime has been committed, law enforcement officials look for the remains of victims, personal property of victims, potentially contaminated debris requiring special handling and disposal, and possibly classified or sensitive items or information. Where: Law enforcement personnel will establish several perimeters around the crime scene with restricted access. Typically they will set up outer perimeter(s) to provide points of access to the site and an inner perimeter close to the actual crime scene where the debris is most likely to be located. Debris operations are likely to occur within the perimeters established by law enforce- ment, and also possibly at areas designated for processing crime scene debris evidence, as was done at the Fresh Kills landfill after the World Trade Center disaster.

114 A Debris Management Handbook for State and Local DOTs and Departments of Public Works When: Debris cannot be moved until approved by appropriate law enforcement officials. Debris removal from small debris-generating events usually begins after the search and rescue or search and recovery phase is complete. Debris removal from large debris-generating events might occur concurrently with the rescue and recovery phases to facilitate rescue and recovery operations and preserve evidence. For example, one sector of the crime scene area might be released by law enforcement officials so debris removal from that area can begin while crime scene investigations in other sectors are ongoing. Who: Local, state, and federal law enforcement personnel coordinate access to the crime scene and all on-site operations within the established perimeters. Fire and rescue personnel conduct life-saving and search and rescue operations, and could require the assistance of the departments of public works, solid waste, transportation, and other local department personnel and equip- ment during rescue operations. Coordination with structural engineers might also be required to safely move debris to rescue trapped victims. If any type of contamination at the site is suspected, state and federal environmental personnel will oversee proper use of appropriate PPE as well as appropriate decontamination processes for workers and equipment prior to leaving the site. As the rescue mission transitions to one of recovery, the handling of human remains is coordinated between law enforcement personnel and the medical examiner’s office. Debris removal work, whether accomplished by local resources, contractor personnel, or federal assets through a mission assignment, continues to be closely coordinated by the debris manager with law enforcement personnel. Because of the nature of the work, personnel should be rotated frequently in consideration of their psychological well-being. How: All debris removal work must be done in close coordination with law enforcement and rescue personnel. Because all access points to the crime scene and therefore debris locations are closely controlled by law enforcement personnel, the debris manager needs to identify who will perform the work and what equipment is used. These people and equipment need to be creden- tialed in accordance with security procedures established for the disaster. The individuals who are identified to work within the crime scene perimeters also must be trained in evidence awareness and the proper use of heavy equipment to perform search and rescue operations. They also likely need certifications to work in a hazardous environment. Within the crime scene perimeters, no debris should be moved, picked up, or even touched without specific approval by a designated law enforcement official. Once a law enforcement offi- cial has indicated that debris can be moved, chain of custody will be established and documented from point of pick up to point of release. This process usually is done in cooperation with law enforcement personnel. If debris that is collected is subsequently identified as potential evidence, it should be documented with the names of the equipment, operators/drivers, date, time, and work zone/location of pickup. If law enforcement determines that debris needs to be examined for evidence at a remote site, the debris being transported for processing should be accompanied by or monitored by a law enforcement officer until it has been delivered and chain of custody has been transferred. The remote site will have its own logging, tagging, and receiving area. Depending on the nature of the incident, there may be a need for two sites—one for hazardous debris and one for non-hazardous debris. Segregating large debris pieces such as large metal debris from other debris can help expedite operations. Shaker screens can be used to further segregate the remaining debris for additional analysis. Using a conveyor belt provided by the debris operations agency or contractor to analyze and segregate the smaller debris pieces makes the process easier and more productive for law enforcement personnel (49). The debris manager might also be asked to provide some weatherproof shelters for workers to continue evaluating and sorting debris during periods of inclement weather. Some sort of refrigerated storage should be available to store evidence.

Special Considerations 115 Separate refrigerated storage could be requested from debris operations management by the medical examiner, if needed for human remains. As debris is processed and released, it should be processed and disposed of in accordance with the local jurisdiction’s debris management plan. If the disaster is a non-conventional weapons of mass destruction–type of event, local agencies are likely to be the first responders on site until state and federal resources arrive. Federal agencies are likely to be tasked with performing much of the long-term recovery work, including debris operations, but local government agencies might continue to have a role in these operations. If, during operations, a contaminant is suspected or confirmed, personnel who continue to work at the site must be trained in the use of the appropriate level of PPE, and OSHA certification to work on hazardous site will likely be required. Debris removal work will be slow because of the precautions that will be required to remove and transport the debris. For example, all debris will have to be containerized prior to transporting it off-site.

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TRB’s National Cooperative Highway Research Program (NCHRP) Report 781: A Debris Management Handbook for State and Local DOTs and Departments of Public Works provides debris management practices for local, tribal, and state departments of transportation and for public works agencies. A PowerPoint presentation and a final report describing the methodology of the project are available online.

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