Greenville_County_Debris_Management_Plan_2008.pdf

GREENVILLE COUNTY

DISASTER DEBRIS MANAGEMENT PLAN

APRIL 2008

Table of Contents

STAFF DEVELOPMENT & RESPONSIBILITIES

CONTRACT AND COOPERATIVE AGREEMENTS

DISASTERS

ESTIMATING DEBRIS QUANTITIES

HEALTH AND SAFETY

MONITORING

DEBRIS REMOVAL PRIORITIES

STORGAGE AND REDUCTION SITES

DEBRIS CLASSIFICATION

DEBRIS DISPOSAL AND REDUCTION

DEBRIS MANAGEMENT ACTIONS

APPENDICES

Appendix A Notice to Public Appendix B Pre Event Contract Appendix C Right of Entry Agreement Appendix D Temporary Storage Site List Appendix E County Road Priority List Appendix F Hazard Assessment Form Appendix G Regulatory Permit Guidance Appendix H Monitoring Training Appendix I Equipment and Personnel Reporting Forms

DEBRIS MANAGEMENT PLAN

GREENVILLE COUNTY, SOUTH CAROLINA

APRIL, 2008

MISSION

• Facilitate and coordinate the removal, collection, and disposal of debris following a disaster.

• Mitigate against any potential threat to the health, safety, and welfare of the impacted citizens.

• Expedite recovery efforts in the impacted area.

• Address any threat of significant damage to improved public or private property.

SITUATION

Natural and man-made disasters precipitate a variety of debris that includes, but is not limited to, such things as trees, sand, gravel, building/construction materials, vehicles, personal property, etc.

The quantity and type of debris generated from any particular disaster is a function of the location and kind of event experienced, as well as its magnitude, duration, and intensity.

The quantity and type of debris generated, its location, and the size of the area over which it is dispersed directly impacts the type of collection and disposal methods used to address the debris problem, associated costs incurred, and the speed with which the problem can be addressed.

The Debris Management Plan implemented by Greenville County will be based on the waste management approach of reduction, reuse, reclamation, resources recovery, incineration, and landfilling, respectively.

ORGANIZATION AND CONCEPT OF OPERATIONS

The Greenville County Public Works Department (Public Works) is responsible for the debris removal function. Public Works will work in conjunction with designated public and private support agencies, utility companies, and waste management firms to facilitate the debris clearance, collection, reduction, and disposal needs following a disaster. Public Works will be responsible for removing debris from the public right-of-way. Only when preapproved by the County Administrator will Public Works remove debris from private property.

Because of the limited quantity of resources and service commitments following the disaster, Greenville County may be relying heavily on private contractors to remove, collect, and manage debris for reuse, resource recovery, reduction, and disposal. Using private contractors instead of government workers in debris removal activities has a number of benefits. It shifts the burden of conducting the work from Greenville County to the private sector, freeing up government personnel to devote more time to their regularly assigned duties. Private contracting also stimulates local, regional, and State economies impacted by the storm, as well as maximizes State and local governments' level of financial assistance from the Federal government. Private contracting allows Greenville County to more closely tailor their contract services to their specific needs. The entire process (i.e., clearance, collection, transporting, reduction, and disposal, etc.) or segments of the process may be contracted out.

Public Works has developed and will maintain a list of selected contractors who have the capability to provide debris removal, collection, and disposal in a cost effective, expeditious, and environmentally sound manner following a disaster. These contractors were chosen in advance through a competitive bidding process consistent with the Greenville County Procurement Ordinance. The Request for Proposals and contract are included in Appendix B

STAFF DEVELOPMENT & RESPONSIBILITIES

Greenville County has selected a Debris Manager to supervise a Debris Management Team.

The Debris Manager is the Transportation/Infrastructure Engineer and the team will be comprised of the following personnel:

1. Administration – Public Works Administrative Assistant Function: supply acquisition, force account record-keeping, contractual accounting

2. Contracting and Procurement – Procurement Services Director Function: Bidding requirements, advertisements for bids, instructions to bidders, contract development, insurance requirements, procurement cards

3. Legal – County Attorney Function: Contract review, right of entry permits, County ordinance interpretation

4. Operations – Public Works Superintendents Function: Supervision of government and contract resources (both collection and collection monitoring), identification of tasks, preparation of estimates

5. Engineering – Code Enforcement and Property Management Function: Detailed damage assessment of public and private structures, identification of project tasks, preparation of estimates, plans, specifications

6. Debris Disposal – Solid Waste Manager

Function: Determination and management of temporary and permanent debris disposal sites, recycling and reclamation coordination, management of debris site monitoring

7. Public Information – Public Information Officer Function: Coordinate press releases, contacts with media, public notices for debris removal

The staff shall coordinate with all State and Federal agencies responsible for disaster response and recovery operations. The staff will be assigned the task of:

1. Implementing the Debris Management Plan

2. Developing an estimate of the debris related to the disaster

3. Developing public information

4. Training personnel in debris management techniques

5. Maintaining pre-disaster maps, photos and other documents

6. Maintaining a list of critical facilities (streets, roads, and bridges)

CONTRACT AND COOPERATIVE AGREEMENTS

Pre-existing contracts are in effect to allow Greenville County to expedite their implementation in a prompt and effective manner.

Public Works will be responsible for managing the debris contract from project inception to completion. Managing the debris contract includes such things as monitoring of performance, contract modifications, inspections, acceptance, payment, and closing out of activities.

Greenville County may enter into cooperative agreements with other public agencies and local governments to maximize public assets.

The three types of contracts that may be used are the:

1. Time and Materials Contract Limited to the first 70 hours of operation and only after all local equipment has been committed. The price for equipment applies only when the equipment is operating, Greenville County can terminate the contract at its convenience, and does not guarantee a minimum number of hours.

2. Lump Sum Contract The price of the work is fixed unless there is a change in the scope of work to be performed. Lump sum contracts will be calculated on either the “area” method or the “pass” method. The lump sum contract shall only be used when the scope of work is clearly defined and the areas of work can be specifically quantified.

3. The Unit Price Contract The most accurate account of actual quantities removed.

Requires field inspectors to eliminate contractor fraud. All contractor trucks must be measured. Requires load tickets identifying truck number, contract number, contractor’s name, date, time departed site, and estimated volume.

Standard contracts are attached in Appendix B.

Greenville County may identify certain volunteer agencies ready to assist. These agencies could include Civic Clubs, Church organizations, or the Salvation Army. The Debris Manager will coordinate these volunteer organizations.

DISASTERS

Greenville County’s population is estimated to be over 407,383 residents (US Census 2005 estimate). In addition to the permanent residential population, thousands commute into Greenville County each day to work. Greenville County encompasses 790 square miles ranging from urban to rural in area. As the states’ most populated county, combined with a large daily influx of workers, transients, and tourists, Greenville County can experience a loss of life and property of catastrophic proportions due to an array of hazards. The following statistics illustrate the vulnerability of the county’s population.

(1) Approximately twelve (12) percent (48,071) of the county’s total population is 65 years of age and older (US Census 2004)

(2) Over ten (10) percent (407,383) of South Carolina’s population resides in Greenville County

(3) There are over 60,000 K –12th grade children in Greenville County’s public schools.

(4) There were estimated to be over 25,000 Manufactured Housing Units in Greenville County in 1999 (Greenville County Planning Commission)

(5) A large portion of the county’s population live in urban settings, therefore a potential disaster could impact a larger percentage of the population.

Hazard Analysis

Greenville County is subject to many potential disasters both natural and man-made. The threat posed by these hazards is both immediate (e.g., hazardous chemical spill, hurricane, tornado) and long-term (e.g., drought, chronic chemical release). These hazards have the potential to disrupt day-to-day activities, cause extensive property damage, and create mass casualties.

Although the county has sufficient material goods, staffing, and expertise to meet routine requirements, a catastrophic disaster could exhaust the resources and overtax its capability. All available assets must be organized under one plan to assure effective operations during an emergency or disaster. Possible hazards include:

a) Hurricanes and Tropical Storms

Although hurricanes are primarily thought of as a coastal phenomenon, inland counties may be directly affected by these storms. Effects include high winds, tornadoes, and inland flooding associated with heavy rainfall, which usually accompanies hurricanes and tropical storms. Greenville County has experienced ten (10) hurricanes or tropical storms over the past 155 years. In 1995, Tropical Storm Jerry distributed up to 18 inches of rain in parts of Greenville County, and caused millions of dollars in property damage and the loss of several lives in the upstate. More detailed information concerning hurricanes and tropical storms is included in the South Carolina Hurricane Plan.

b) Tornadoes

Greenville County has seen eighteen tornadoes over the past fifty-six years. As a county, it is ranked fourth in the State for vulnerability to tornados (State of South Carolina Hazards Assessment, 2005). The most common type of tornado, the relatively weak and short-lived type, occurs most often between March and May.

However, tornadoes can occur almost anywhere at anytime.

c) Riverine Flooding

In Greenville County, several variations of flood hazards occur due to the different effects of severe thunderstorms, tropical storms, seasonal rains and other weather-related conditions. The county’s topography, combined with its humid climate, makes it highly vulnerable to inland or riverine flooding. Greenville County has experienced 110 floods in the past thirty-one years and was ranked first in the State for vulnerability to floods (State of South Carolina Hazards Assessment, 2005). Riverine flooding occurs when the flow of rainwater runoff is greater than the carrying capacities of the natural drainage systems.

Recent flooding experiences include the Greater Greenville Flood which occurred in March of 2003. This event caused $1.3 million in property damage in Greenville County. Flooding was significant in the communities of Berea, Taylors, and Mauldin. Another flood occurred in September, 2004 that affected Oconee and Greenville counties. Widespread flooding of creeks and streams caused an estimated $2.6 million in property damage and $5 million in crop damage.

On July 29, 2004 a large flash-flood event in Greenville caused $3.5 million in property damage from major flooding in areas from Berea to downtown Greenville city. The Reedy River crested at 19.2 feet in downtown Greenville, the second highest level on record (NCDC Storm Data reports online, 2006). A flash flood in July, 2005 in Greenville County caused $1.8 million in property damage and resulted in the rescue of more than 100 people from various locations in the county.

d) Severe Winter Weather

Snow and ice storms, coupled with cold temperatures, periodically threaten the county. Winter storms can damage property, create safety risks, destroy crops and valuable timber, damage infrastructure components such as power lines, and have enormous economic impacts. Snow and ice storms have occurred in Greenville County in 1989, 1993, 2000, and 2002. Most recently, in 2005, a Presidential Disaster Declaration resulted from an ice storm in the county. The 2005 version of the State of South Carolina Hazards Assessment, ranked Greenville County first in the State for vulnerability to winter storms (2002).

e) Earthquakes

Greenville County had 3 earthquakes in 1999, each ranging between 2.0 – 2.4.

All 3 occurred in the Sandy Flat area of the county. Recently, Greenville County ranked eighth in the State for vulnerability to earthquakes (State of South Carolina Hazards Assessment, 2005).

f) Fires

In a typical year, South Carolina responds to over 5000 wildfires, which burn nearly 30,000 acres. South Carolina’s wildfire season usually occurs between late winter and early spring. Greenville County ranked twelfth in the State for vulnerability to wildfires (State of South Carolina Hazards Assessment, 2005).

g) Terrorism

(1) Governmental, transportation, commercial, infrastructure, cultural, academic, research, military, athletic and other activities and facilities constitute ideal targets for terrorist attacks which may cause catastrophic levels of property and environmental damage, injury, and loss of life. Furthermore, a variety of extremist groups are known to operate within Greenville County.

(2) Terrorist attacks may take the form of other hazards described in this section when incidents of these types are executed for criminal purposes, such as induced dam or levee failures.

h) Dam Failure

Greenville County has 19 class 1 dams (high hazard), and 31 class 2 dams (significant hazard). At any time, one or more of these dams may be threatened by upstream flash floods, earthquakes, neglect, or any combination of the above, which can cause personal injury or death, significant water damage to property or additional failures to dams located downstream.

A detailed hazard analysis by county can be found in the State of South Carolina Hazard Assessment, September 2005. A Hazard Rating Summary, which is based on this assessment and provides a relative ranking of the hazards found in Greenville County, can be found in Attachment A of the State’s Hazard Assessment.

ESTIMATING DEBRIS QUANTITIES

The formula for estimating debris quantity is: Q=H(C)(V)(B)(S)

H (Households)=Population/3 (3 persons per household) C (Category of Storm)=Factor (See table below) V (Vegetation Multiplier)= Factor (See table below) B (Commercial Density Multiplier)= Factor (See table below) S (Precipitation Multiplier)= Factor (See table below)

Hurricane Category Value of “C” Factor

1 2 CY

2 8 CY

3 26 CY

4 50 CY

5 80 CY

Vegetative Cover Value of “V” Multiplier Light 1.1 Medium 1.3 Heavy 1.5

Commercial Density Value of “B” Multiplier Light 1.0 Medium 1.2 Heavy 1.3

Precipitation Value of “S” Multiplier None to Light 1.0 Medium to Heavy 1.3

Once the amount of debris has been estimated, the County will require temporary storage sites the size of which can be determined by taking the following factors into consideration:

1. The debris pile shall be stacked to a height of no more than 10 feet.

2. 60% usage of the land area will be devoted to roads, safety buffers, burn pits, household hazardous waste, etc.,.

3. 10 foot stack height = 3.33 yards

4. 1 acre = 4,840 square yards (sy)

5. Total volume per acre = 4,840 sy/ac x 3.33y = 16,133 cy/ac.

Using the above assumptions, the estimate of total debris from any hurricane will be within 30% plus or minus of the actual amount of debris accumulated.

It is estimated that under the worst scenario, e. g., a Category 5 hurricane, heavy vegetation cover, heavy commercial density, and heavy precipitation, the amount of acres needed for a temporary landfill is 1,875 acres. The calculation (assuming an affected population of 270,000 (2/3 of total)) is as follows:

Q = 90,000 x 80 x 1.5 x 1.3 x 1.3 Q = 18,252,000 cy of debris 18,252,000 (cy of debris / 16,133 (cy/ac) = 1,130 acres of debris.

1,130 acres x 1.66 (60% more area needed for roads, ,etc.,.)= 1,875 acres.

HEALTH AND SAFETY

Prior to commencement of debris removal, all County personnel should be familiar with current Greenville County Health and Safety procedures. The procedures are specifically detailed in “The County of Greenville Safety Policy”. All existing employees should have received training regarding basic protocols.

Appendix F contains a Hazard Assessment Form which provides a detailed description of personal protective equipment that would be applicable during debris collection and management of the temporary storage areas. In addition, all contractors should have a current Health and Safety plan. All contract employees should be thoroughly trained and provided with all necessary equipment to perform their tasks safely.

MONITORING

In compliance with FEMA requirements, it is the responsibility of Greenville County to independently monitor all debris activities, whether performed by their own force account labor or contract. Specifically:

• all materials to be collected will be documented by the monitor to be eligible for reimbursement prior to collection

• all vehicles will have a volume calculated prior to use; the volume will be clearly posted on the vehicle

• once loaded, all loads will be estimated following the FEMA document, “Local Monitor Guidelines for Estimating Quantities of Debris in Trucks”

• daily documentation will be maintained to record load estimates

• at each temporary storage facility, the incoming loads will be recorded

Monitors will be trained prior to assignment in the field. Training will include a definition of debris types, reimbursement eligibility, and methods for truck volume estimating. Monitors will report any concerns to either the Public Works Superintendents or the Solid Waste Manager depending upon the monitoring location.

Appendix H contains standard forms for use by monitors.

DEBRIS REMOVAL PRIORITIES

The debris removal process must be initiated promptly and conducted in an orderly, effective manner in order to protect public health and safety following a major or catastrophic event. To achieve this objective, the first priority will be to clear debris from key roads in order to provide access for emergency vehicles and resources into the impacted area. Key roads are identified in Appendix E.

The need and demand for critical services will be increased significantly following a disaster.

Therefore, the second priority that debris removal resources will be assigned is providing access to critical facilities. Critical facilities have been identified as:

1. Greenville Memorial Hospital

2. St. Francis Hospital Downtown

3. Hillcrest Hospital

4. North Greenville Hospital

5. St. Francis Women’s Hospital

6. Patewood Memorial Hospital

7. St. Francis Hospital Eastside

The third priority for the debris removal teams to address will be the elimination of debris related threats to public health and safety. This will include such things as the repair, demolition, or barricading of heavily damaged and structurally unstable buildings, systems, or facilities that pose a danger to the public. Any actions taken to mitigate or eliminate the threat to the public health and safety must be closely coordinated with the owner or responsible party. If access to the area can be controlled, the necessary actions can be deferred.

Actions to eliminate threats on private property will follow the existing Greenville County procedures for evaluation of Unfit Structures (Appendix C).

STORGAGE AND REDUCTION SITES

In addition to disposal at the landfill, debris will be placed at storage and reduction sites determined before the onset of the disaster. The debris will either be reduced and recycled at these sites or later transported to the landfill. Temporary debris collection sites will be readily accessible by recovery equipment and will not require extensive preparation or coordination for use. Collection sites will be on public property to facilitate the implementation of the mission and mitigate against any potential liability requirements. Activation of sites will be under the control of the Debris Manager and will be coordinated with other recovery efforts through the emergency operations center.

The following is a list of debris storage and reduction sites as identified in Appendix D. These sites have been and will continue to be evaluated by County personnel who are familiar with the area.

1. Blackberry Valley Landfill

2. O’Neal Convenience Center

3. Enoree Landfill

4. Piedmont Landfill

5. Simpsonville Convenience Center

Each temporary debris storage and reduction site will eventually be emptied of all material and be restored to its previous condition and use.

Current photos will be maintained to note important features such as structures, fences, culverts, and landscaping. Since all sites are closed landfills, water samples from existing wells are routinely taken.

After activities begin, monitoring of air quality will take place. Photos, maps, and sketches of the site will be updated and fuel spills will be noted.

At closeout final testing of soil, water, and air quality will be compared to original conditions.

All ash will be removed and any remediation actions will be taken.

DEBRIS CLASSIFICATION

To facilitate the debris management process, debris will be segregated by type. The County will adopt the categories established for recovery operations by the U.S. Army Corps of Engineers following Hurricane Andrew. Debris removed will consist of two broad categories:

clean wood debris and construction and demolition (C&D) debris. Of the mixed C&D it is estimated 42% will be burnable but require sorting, 5% will be soil, 15% will be metals, and 38% landfill materials. Depending upon the quantity of materials and their proximity to each other, they may be collected separately to promote recycling (i.e. separate collection for appliances).

Definition of classifications of debris are as follows:

1. Burnable Materials: Burnable materials will be of two types with separate burn locations:

a. Burnable Debris: Burnable debris includes, but is not limited to, damaged and disturbed trees; bushes and shrubs; broken, partially broken and severed tree limbs; and bushes. Burnable debris consists predominately of trees and vegetation. Burnable debris does not include garbage or construction and demolition material debris.

b. Burnable Construction Debris: Burnable construction and demolition debris consists of non-creosote structural timber, wood products, and other materials designated by the coordinating agency representative.

2. Non-burnable Debris: Non-burnable construction and demolition debris includes, but is not limited to, creosote timber, plastic, glass, rubber and metal products, sheet rock, roofing shingles, carpet, tires, and other materials as may be designated by the coordinating agency. Garbage will be considered non-burnable debris.

3. Stumps: Stumps will be considered tree remnants exceeding 24 inches in diameter; but no taller than 18 inches above grade, to include the stump ball. Any questionable stumps shall be referred to the designated coordinating agency representative for determination of its disposition.

4. Ineligible Debris: Ineligible debris to remain in place includes, but is not limited to, chemicals, petroleum products, paint products, asbestos, and power transformers.

Any material that is found to be classified as hazardous or toxic waste (HTW) shall be reported immediately to the designated coordinating agency representative. At the coordinating agency representative’s direction, this material shall be segregated from the remaining debris in such a way as to allow the remaining debris to be loaded and transported. The HTW will be collected separately for disposal or recycling as dictated by type (i.e. oil recycling).

Standing broken utility poles, damaged and downed utility poles and appurtenances, transformers and other electrical material will be reported to the coordinating agency representative. Emergency workers shall exercise due caution with existing overhead and underground utilities and above ground appurtenances, and advise the appropriate authorities of any situation that poses a health or safety risk to workers on site or to the general population.

DEBRIS DISPOSAL AND REDUCTION

Once the debris is removed from the damage sites, it will be taken to the storage and reduction sites. The three methods of reduction are burning, recycling, and grinding/chipping.

1. Burning

The three primary burning methods are open burning, air curtain pit burning, and incineration.

Controlled open burning is a cost-effective method for reducing clean woody debris in rural areas. Burning reduces the volume by 95%, leaving only ash residue to be disposed. Air curtain pit burning substantially reduces environmental concerns. The blower unit must have adequate air velocity to provide a “curtain effect” to hold smoke in and to feed air to the fire below. Portable incinerators use the same methods as air curtain pit systems. The only difference is that portable incinerators utilize a pre-manufactured pit in lieu of an onsite constructed earth/limestone pit.

Prior to any burning, all necessary permits will be obtained from the South Carolina Department of Health and Environmental Control (SCDHEC). Applying for and obtaining the permits will be the responsibility of the Solid Waste Division which is responsible for final disposal. Appendix G contains a regulatory permit guidance which has been used in past natural disasters. This guidance along with direct contact with both local and state SCDHEC representatives will facilitate the expeditious obtainment of permits.

2. Recycling/Reduction

Metals and untreated wood are prime candidates for recycling. Most of the non-ferrous metals are suitable for recycling. Current metal recycling contractors are available to provide disposal of debris by recycling if it is well sorted. In most cases, recyclable metals will be collected separately and transported to a specified location for processing and transportation by the recycling contractor.

Grinding and chipping will be utilized as a viable reduction method for untreated wood.

Suitable materials will be collected curbside for transport to the temporary storage sites. Once at the sites, the wood will be separated for processing by the grinder. Grinding and chipping reduces the volume on a 4 to 1 ratio. For grinding and chipping to be feasible, 25% of volume remaining must have some benefit or use. Current giveaway procedures will be implemented at the temporary storage sites to facilitate distribution of chipped wood material to local residents along with public and private landscapers. Information regarding the material will be publicized through the media as well as by direct contact with local agencies.

DEBRIS MANAGEMENT ACTIONS

The Debris Management Plan is separated into four stages:

1. Normal Operations

a. Advertise and execute contracts with large contractors to assist in all phases of debris management.

b. Develop local and regional resource list of vendors who can assist Greenville

County in minor debris management tasks.

c. Develop mutual aid agreements with other agencies and local governments, as appropriate.

d. Identify potential debris storage and reduction sites for the type and quantity of debris anticipated following a catastrophic event.

e. Pre identify local and regional critical routes in cooperation with contiguous and regional jurisdictions.

f. Identify and coordinate with appropriate regulatory agencies regarding potential regulatory issues and emergency response needs.

g. Develop the necessary right of entry and hold harmless agreements indemnifying all levels of government against any potential claims.

h. Establish debris assessment process to define scope of problem.

i. Develop and coordinate pre-scripted announcements with the Public Information

Office (PIO) regarding debris removal process, collection times, temporary storage sites use of private contractors, environmental and health issues, etc.

2. Increased Readiness (A natural or man-made disaster is threatening the local area)

a. Review plans, standard operating procedures, and checklists relating to debris removal, storage, reduction, and disposal process.

b. Alert local departments that have debris removal responsibilities ensuring that personnel, facilities, and equipment are ready and available for emergency use.

c. Relocate personnel and resources out of harm's way and stage in areas where they can be effectively mobilized.

d. Review potential local, regional, and debris staging and reduction sites that may be used in the response and recovery phases in the context of the impeding threat.

e. Notify previously contracted vendors to ensure their availability in the event of the disaster.

3. Response

a. Activate debris management plan, coordinate with needs assessment team.

b. Begin documenting costs using equipment and personnel forms (Appendix I)

c. Coordinate and track resources (public and private).

d. Establish priorities regarding allocation and use of available resources.

e. Identify and establish temporary debris storage and reduction sites.

f. Address any legal, environmental, and health issues relating to the debris removal process.

g. Continue to keep public informed through the PIO.

4. Recovery

a. Continue to collect, store, reduce, and dispose of debris generated from the event in a cost-effective and environmentally responsible manner.

b. Continue to document costs.

c. Upon completion of debris removal mission, close out debris storage and reduction sites by developing and implementing the necessary site restoration actions.

d. Perform necessary audits of operation and submit claim for Federal assistance.

Appendix A Notice to Public

Appendix B Pre Event Contract

Appendix C Right of Entry Agreement

Appendix D Temporary Storage Site List

Appendix E County Road Priority List

Appendix F Hazard Assessment Form

Appendix G Regulatory Permit Guidance

Appendix H Monitoring Training

Appendix I Equipment and Personnel Reporting Forms

DEBRIS MANAGEMENT ACTIONS