&EPA
           United States
           Environmental Protection
           Agency
           Office Of Water
           (4602)
EPA 440/6-90-O03
May 1990
Guide To
Ground-Water Supply
Contingency Planning For
Local And State Governments
Technical Assistance
Document

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GUIDE TO GROUND-WATER SUPPLY
  CONTINGENCY PLANNING FOR
LOCAL AND STATE GOVERNMENTS
          OFFICE OF WATER
   OFFICE OF GROUND-WATER PROTECTION
  U.S. ENVIRONMENTAL PROTECTION AGENCY
             MAY 1990
                                     Printed on Recycled Paper

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                        ACKNOWLEDGEMENTS
     This document was prepared for the Environmental Protection Agency, Office of
Ground-Water Protection (OGWP) under contract number 68-C8-0003.  It is based in part
on a document prepared earlier under contract number 68-01-7332. Mr. Kevin McCormack
and Mr. Steven Roy of OGWP served as Task Managers for this project with assistance
from Dr. Norbert Dee.
Marian Mlay
Director

Office of Ground-Water Protection

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                       TABLE OF CONTENTS
INTRODUCTION	  1

     What Is Contingency Planning?  	. .		  1
     Relationship of Contingency Planning to Wellhead Protection	  2
     Other Federal Requirements for Contingency Planning  	:	  4
     Purpose of this Technical Assistance Document		:  4
     Organization of this TAD	  5
     Other Information on Wellhead Protection 	  6
     Other Information on Contingency Planning 	  6

SECTION I  CONTINGENCY PLANNING AT THE LOCAL LEVEL  	  9

     CHAPTER 1: ORGANIZING THE LOCAL PLANNING PROCESS  ....   13

          1.1   FORMING THE PLANNING TEAM 	   13
          1.2   IDENTIFYING THE TEAM LEADER .		   14
          1.3   IDENTIFYING PLANNING PRIORITIES	   17
          1.4   IDENTIFYING AVAILABLE PLANNING RESOURCES	   18
          1.5   ASSIGNING AND MANAGING PLANNING
               RESPONSIBILITIES	   19

     CHAPTER 2: DEVELOPING THE LOCAL PLAN 	   21

         2.1   FOCUSING ON KEY THEMES	   21

         2.2   PLACING THE PLAN IN CONTEXT WITH AN
               "INTRODUCTION"	   23

               Directory of Information	   23
               Legal Authority for the Plan	   23
               Objectives of the Plan	   23
               Overview of the Local Wellhead Protection  Program  	   24
               Summary of Local Planning Needs	   24
               How the Plan was Developed  	   24
               Relationship to Other Planning Efforts	   24
               Plan Distribution	   25
               Procedures for Review and Update	   25
               Amendments and Changes  (with Dates)  	   25

         2.3   DESCRIBING EXISTING CONDITIONS - BACKGROUND
               INFORMATION	   25

               Water System Characteristics	   26
               Potential Sources of Water Supply Disruption	26
               Water Supply Replacement Alternatives	   37
               Logistical Support Resources	   37
               Financial Resources	   42

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                TABLE OF CONTENTS (continued)
         2.4   DEFINING WHO DOES WHAT - EMERGENCY
              RESPONSE PROCEDURES  	  42

              Emergency Identification	  44
              Notification Roster	  47
              Overview of Incident Direction and Control	 .  47
              Internal Communications  	  49
              Public Communications/Community Relations  	  49
              Ongoing Incident Assessment	  50
              Contamination Assessment  	  50
              Special Procedures for Non-Contamination Events	  51
              Obtaining Alternative/Supplementary Water Supplies  	  52
              Water-Use Restrictions	  52

         2.5   ADDRESSING PROBLEMS - FUTURE STEPS TO BE
              TAKEN	  52

              Preventing or Mitigating Emergencies	  52
              Training Local Responders	  54
              Educating the Public	  54
              Reviewing and Updating the Plan	  54

         2.6   BUILDING CONSENSUS FOR THE PLAN	  55

SECTION II CONTINGENCY PLANNING AT THE STATE LEVEL  	  57

     CHAPTER 3:  ORGANIZING THE STATE PLANNING PROCESS	  59

         3.1   ASSESSING STATEWIDE PLANNING NEEDS AND THE
              ROLE OF THE STATE	  59

         3.2   IDENTIFYING THE LEAD AGENCY AND FORMING THE
              STATE PLANNING TEAM	  60

         3.3   IDENTIFYING AVAILABLE STATE PLANNING
              RESOURCES	  60

         3.4   ASSIGNING AND MANAGING PLANNING
              RESPONSIBILITIES	  62

     CHAPTER 4:  DEVELOPING THE STATE PLAN	  63

         4.1   FOCUSING ON KEY THEMES	  63

         4.2   PLACING THE PLAN IN CONTEXT WITH AN
              "INTRODUCTION"	  65

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                 TABLE OF CONTENTS (continued)
          4.3   BACKGROUND INFORMATION  	   65

               Statewide Water System Assessment	   66
               Statewide Ground-Water Supply Vulnerability Assessment	   67
               Statewide Water Supply Replacement Assessment	   70
               State Support Resources .	   70

          4.4   WATER SUPPLY DISRUPTION RESPONSE PROCEDURES
               AND LOCAL PLANNING GUIDANCE		   71

               State Response Procedures 	   71
               Guidance for Local Planning and Response	   74

          4.5   ADDRESSING PROBLEMS -- FUTURE STEPS TO BE
               TAKEN	   76

               Preventing or Mitigating Emergencies	   76
               Training Local Responders	   76
               Reviewing and Updating the Plan	 . .	   76

          4.6 BUILDING CONSENSUS FOR THE PLAN		   77

SECTION III CHAPTER 5: REVIEWING AND UPDATING LOCAL
AND STATE PLANS	   79

          5.1   PLANNING IS A CONTINUOUS PROCESS	   79
          5.2   SUGGESTED PLAN REVIEW TECHNIQUES	   79
          5.3   EXERCISING THE PLAN	   82
          5.4   REVIEWING  SUPPLY DISRUPTION INCIDENTS  	   82

APPENDICES

     Federal Contingency Planning Requirements  	   A-l

     List Of Workshop Participants	   B-l

     Description Of Pilot Projects	   C-l

     Sources Of Information On Contingency Planning	   D-l

     Example Of Hazardous Material Spill Vulnerability Survey
     Checklist	   E-l

     List Of Sources Of Information On Hazardous Materials	   F-l

     Short-Term And Long-Term Replacement Options . .	   G-l

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                 TABLE OF CONTENTS (continued)


APPENDICES (continued)

     Potential Funding Sources	   H-l

     Example Of Emergency Notification Report	    1-1

     Public Education  	    J-l

     Classification Of Water Uses And Option For Dealing With Shortages
     And Water Quality Problems	   K-l

     Support Functions Evaluation	   L-l

     Action Level System	   M-l

     Specific Response Procedures	 . .   N-l

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                          EXECUTIVE SUMMARY
      The purpose  of this Technical Assistance Document is to assist States and local
communities  in establishing,  providing, maintaining,  and  updating  certain emergency
response procedures that may become necessary if a partial or total loss of public water
supply service occurs.  The development and integration of these emergency response
procedures into a workable plan constitutes the Contingency Planning Process.

      The Contingency Planning Process is an integral part of EPA's Wellhead Protection
Program, established under the 1986 Amendments to the Safe Drinking Water Act.  The
Wellhead Protection Program  was developed primarily to  protect the  ground waters that
supply wells and wellfields that contribute drinking water to public water supply systems.
The basic purposes of the program are to  recognize and address the essential need to
protect ground-water  drinking water supplies, and to meet the goals of the Safe Drinking
Water Act.

      Inherent in this combined approach is the need to consider the unique hydrogeologic
environments and potential sources of contaminants or physical disruptions to which these
ground-water drinking water supplies may be exposed and the right of the State and local
entities to determine  how matters of land use and water allocations are best resolved for
individual locations.

      The  periodic occurrence  of  natural  disasters,  chemical  contamination,  physical
disruptions, and civil  disorders all threaten the supply and distribution network of public
drinking water supplies to some degree.  These potential problems may range from a few
hours' inconvenience to a  small service area caused  by a water main break to the
contamination of an entire aquifer supplying drinking water to a major metropolitan service
area.  In either case, the minimization of impact on the public and the timely restoration
of water  supply service to an affected area depends on an updated, efficient, and effective
water supply service contingency plan.

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                               INTRODUCTION
      Although  the  goal of wellhead protection is to prevent the  contamination of
underground drinking water supplies, periodic water supply disruptions may occur.  When
they do, the most effective way to ensure the continued supply of potable water is to have
a contingency plan on hand to direct a coordinated and timely response.
           A tank truck carrying a Ml load of vinyl chloride overturns on a
           higltway located within tfoe recharge zoae lor the shallow acpffer
          . serving as a town's principal water supply.

           Severe Suaanei lightning storms knock omi'thegenerator operating
           the pumps for a romnruaiiy's largest producing wells.

          "As a result of &., waste disposal enforcement "action, the State
           identifies p extensive plume of hazardous leachate moving toward
           & city's we&field.

           Extensive seasonal flooding destroys the pwnp&ouses on a town's
          .wells, all located in a

      Incidents like these are reminders that public water supply systems are vulnerable to
disruption  from many different  threats.  Although threats such  as  flooding and power
outages have  always  been present,  incidents involving contamination of ground-water
supplies are becoming a more common occurrence.  Given that ground-water supplies serve
50 percent of  the U.S. population, the severity of these threats becomes clear.

      The  vulnerability of ground-water supplies points out  the need  for thoughtful
contingency planning to ensure that vital water supplies and public health are safeguarded.
Contingency planning is the only way to ensure the effective and quick coordination of the
wide variety of technical, communications, financial, and administrative activities involved
in responding  to a water supply  emergency.

What Is Contingency Planning?

      The simple answer to this question is that contingency planning is common sense.
More fully, planning  is the identification of potential  threats to  a community's ground-
water supplies and the development of procedures to be  followed when  such  threats
materialize. Contingency plans help communities answer such questions as:

      •     What are the most likely threats to local ground-water supplies?

      •     What specific steps must be taken to address these threats?

      •     Who is responsible for each step and how will response actions be
            coordinated?
            Where can replacement water supplies be obtained?

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                                                                              Page 4
Other Federal Requirements for Contingency Planning

      In addition  to  the  Wellhead  Protection Program,  there  are  other  Federal
requirements for contingency  planning.  Section 1413(a)(5) of the  1974  Safe Drinking
Water Act required that a State must have "adopted ... an adequate plan for the provision
of safe drinking water under emergency circumstances ..." in order to be granted  primary
enforcement  responsibility for public water systems by  EPA.  As a consequence, many
States that have attained primacy under the Act have established emergency plans for the
provision of alternate water  supplies.   In  addition  to these  emergency planning
requirements, Federal Regulations (40 CFR 141.24(g)) require monitoring and vulnerability
assessments of Public Water Supply Systems (PWSSs) in order to address  contamination
by volatile organic compounds (VOCs).  Many of the features of  these ongoing planning
and  other water supply  protection efforts can  be incorporated into the contingency
planning element of the WHP Program required by the  1986 SDWA Amendments.

      Another important Federal statute, the Emergency Planning  and Community Right-
to-Know  Act  of 1986,  enacted  as  Title  III  of the  Superfund  Amendments and
Reauthorization Act (SARA), requires contingency planning of a broader nature.  Title III
establishes a network of  State Emergency Response Commissions (SERCs) and  Local
Emergency Planning Committees  (LEPCs)  charged with  planning for  responses  to
emergency releases of hazardous chemicals. In addition, Title III requires extensive public
reporting by  industrial facilities concerning the presence, quantity, and management of
hazardous chemicals. Title III complements the SDWA ground-water contingency planning
requirements in several important ways:

      •    The local plans developed under Title III (Section 303)  should take
           into account threats to ground-water and thereby provide a starting
           point for contingency plans focused specifically on ground-water;

      •    The "community right-to-know" reporting  (Sections 311 and 312)
           and toxic release inventory (Section 313) requirements of Title III
           provide  a valuable  source  of  information concerning  potential
           contamination threats to ground-water supplies; and

      •    Public   interest  and  participation  generated  by   Title  III
           implementation efforts  should provide  a strong  foundation  for
           similar public involvement in ground-water protection and planning
           efforts.

Appendix A provides the statutory language related to the WHP Program, the Section 1413
emergency plans, and SARA Title III.

Purpose of this Technical Assistance Document

      This Technical Assistance Document (TAD) can help States and communities satisfy
the contingency planning requirements of the 1986 SDWA Amendments, as well as SARA
Title III requirements and the monitoring and vulnerability assessment activities required
of PWSSs. This TAD specifically focuses on  planning for public ground-water supplies.
However, the planning framework presented here is, for  the most  part, equally applicable
to surface-water systems.   This TAD also is  designed  for  use primarily  by  smaller
communities  that lack extensive planning or technical resources, with the belief that larger
communities  will have the resources necessary to develop plans specialized  for their own
particular needs.  Finally,  because it is more efficient to plan for all types of disruption at
one  time, this TAD addresses contingency planning for  all water  supply disruptions,  not
just  those related to contamination  as specifically required under the SDWA.

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            Local communities differ  with respect to political,  institutional, and hydrologic
      conditions, as well as technical and financial capabilities. Such differences must be taken
      into account in determining how  (and by whom) a plan will be developed, on which supply
      disruption threats planning efforts will be focused,  and in defining the procedures to be
      followed in responding to those threats. This TAD does  not provide a planning recipe that
      must be  followed  to  ensure success;  instead, it identifies  a  broad range  of planning
      considerations and describes a structured process through which a community  can target
      those considerations most relevant to local conditions and needs.

            The initial draft of this TAD was completed  in 1987.  Using the draft TAD, EPA
      undertook six pilot contingency  planning projects in towns and cities across the  nation,
      including: Corning, New York;  Palmer, Massachusetts; Jackson, Tennessee; Sioux Falls,
      South Dakota; Oakley, Kansas; and  Tucson,  Arizona.   Working with local officials from
      these communities, EPA gained valuable insight into local preferences and needs and the
      assets and shortcomings of the TAD itself.  The "lessons learned" in those projects have
      been incorporated throughout this document.7 (Appendix C provides brief descriptions of
      each of these projects.)

      Organization  of this TAD

            This TAD is divided into three sections  - the first  focuses on local contingency
      planning, the second  on planning  at  the  State level,  and  the third  on the process of
      reviewing and updating  contingency  plans.  The organization of the first two sections is
      parallel:

             •    The initial chapter of each section (Chapters 1 and 3) focuses on
                  organizing the planning process. Specific topics include organizing
                  the planning team,  selecting  a  team  leader,   setting  planning
                  priorities, identifying planning resources, and assigning planning
                  responsibilities.

             •    The second  chapter of each section (Chapters 2 and 4) focuses on
                  the concrete steps of developing a contingency plan. Specific steps
                  include gathering background information, specifying  response
                  procedures,  and identifying future steps  to be  taken to prevent
                  emergencies, educate the public,  and update the plan.

             •    Finally, Section 3 describes procedures for reviewing and updating
                  a plan. Several review  techniques are  presented as are different
                  methods of exercising the plan.  Section  3 also addresses plan
                  review in the aftermath  of a supply disruption.

       Following the main body of this TAD, there are a series of appendices providing more
       detailed information on many of the topics covered in  the text as well as other materials
       such as bibliographies of useful  publications  and lists of funding sources.
    ; This TAD also incorporates information gathered from a varied group of Federal, State, and local
water supply and emergency response experts who participated in a contingency planning workshop  held
in Washington, D.C. on January 27-28, 1988.  A list of workshop participants is provided in Appendix B.

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                                                                               Page 6
 Other Information on Wellhead Protection

      In  response to the 1986  SDWA Amendments, EPA's Office of Ground-Water
 Protection has developed several TADs, in addition to this document, for State and local
 governments interested in developing Wellhead Protection Programs:

      •     Local Financing for Wellhead Protection (June 1989);

      •     Wellhead Protection Programs: Tools for Local Governments (April
            1989);

      •     Developing A State Wellhead Protection Program: A User's Guide to
            Assist State Agencies Under the Safe Drinking Water Act (July 1988);

      •     Model Assessments for Delineating Wellhead Protection Areas (May
            1988);

      •     State Wellhead Protection Program Question and Answer Fact Sheet
            (June 1987);

      •     Guidelines for the Delineation of Wellhead Protection Areas (1987);

      •     Guidance For Applicants  For State Wellhead Protection  Program
            Assistance Funds Under the Safe Drinking  Water Act (June 1987);
            and

      •     Wellhead Protection: A Decision Makers' Guide (May 1987).

      Additional  information  can be  obtained  from  EPA Regional  Ground-Water
Representatives as shown in Exhibit 1-2.

Other Information on Contingency Planning

      State  and local officials  may turn to many other sources for additional guidance in
undertaking the contingency planning process. (Appendix D provides a fairly extensive list
of such sources.) Particularly helpful is the Hazardous Materials Emergency Planning Guide,
published by the National Response Team, the body charged with coordinating Federal
agency response to hazardous materials emergencies. Although this guide focuses on Title
III hazardous materials planning, the suggestions it provides on the planning process and
sources of planning information should be useful  for water supply planners as  well.

      Local planners might also check to see if guidance has been developed by  their State
water agency.  In some States with their own contingency planning requirements, guidance
documents have been prepared that address both the specific requirements that  must be
met as well as more general planning concepts.

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                                               Exhibit 1-2
              EPA Regional Ground-Water Representatives
Robart Mandoza
Offloa of Ground Wafer
Wafer Managamant DMeton
U.S. EPA, Ragton I
JFKBuiOlng. Room 2113
Boston. MA 02203
(617)566-3800

JohnMatock
Offloa of Ground Wafer
Wafer Managamant DlvWon
U.S. EPA. Ragton II
26 Fadaral Plaza
NawYork. NY 10278
(212)  264-5636

Stuart Kannar
Offloa of Ground Wafer
Wafer Managamant DMaton
U.S. EPA. Ragtan III
84lChaatnutStiMt
Philadelphia. PA 19108
(215) 597-8826
StaWnQB HOWM
Offloa of Ground Wafer
Wafer Managwnont OivWon
U.3. EPA, R^tan IV
346 CourUnd SUM*. NE
Afltnfe.GA 30306
(404) 347-3868

Jarri-Ama Gut
Offloa of Ground Wafer
Wafer Managafmnt DMatan
US. EPA.RagionV
230 S.rjaarbom Stoat
Chtoago.lL 60S04
(312) 888-1490

ErfeoaAlfen
Oflto* of Qrounel Wafer
Wrtw Dtamgwrant DivMon
U.S. EPA, R^tonVI
1446 ROM AVWIM
D*M.TX 75203-2733
(214) 66S-4446
DonTbHMino
OMo* of Ground Wafer
Wafer MamoMtNr* OKMon
U.S. EPA, Raglan VII
726MlnrHHOlBAv«KW
KMauCtty. KS1 68101
(913)238-2970

JanwaOunn
Offlea of Ground Wafer
Wafer Mmgamant OivWon
U.S. EPA, Ragkin VIII
WHamMulan
Offioa of Ground Wafer
Wafer Managamant OMaton
U.S. EPA. R^ionX
1200 891 Avanue
Saataa, WA 98101
(206) 442-1216
Oanvar. Colorado 80202-2406
(303) 293-1709

Deborah Robinton
Offloa of Ground Wafer
Wafer Managamant OivWon
U.S. EPA. Raglan IX
215 Fremont Slrtal
S«l Francfeoo. CA 94106
(415) 974-0831

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                                                                             PageS>
                                  SECTION I

        CONTINGENCY PLANNING AT THE LOCAL LEVEL
      As part of a WHP Program, Section 1428(a) of the SDWA Amendments of 1986
specifies that each public water supplier within a state must provide a contingency plan for
the location and provision of alternate drinking water supplies in the event of well or
wellfield contamination. This initial section of the TAD focuses on contingency planning
at the community level.  Because public water supply is predominantly a local government
function, most responses to supply disruption will occur at the local level.  Section II of
the TAD describes the State role in contingency planning. Exhibit 1-3 provides both a
flow chart of the planning process as well as a "road map" of Section I:

      •    Chapter 1 focuses on getting the planning process started; and

      •    Chapter 2 addresses what to do  once  the planning process  is
           underway  and concludes with some advice on building consensus
           for the plan.

      Before discussing the planning process, it is worth previewing several key themes,
each based on the experience of contingency planners in many communities, that appear
in this TAD:

      •    Build broad community involvement into  the planning  effort,
           including  on the planning  team all parties who will respond to
           water supply disruptions;

      •    Focus planning on the most likely supply disruption threats and
           tailor response actions to community conditions and resources;

      •    Take advantage of available planning resources, including local
           expertise,  existing planning documents, and  help from State and
           Federal agencies;

      •    Think  of a contingency plan as a "living" document requiring
           periodic review and updating to ensure that it continues to reflect
           community conditions; and

      •    Use the planning process  and the plan itself to  identify those
           immediate and longer-term actions  that can be taken to lessen the
           chances of a water supply disruption and to mitigate the impacts
           of those disruptions  that do occur.

      Beginning the planning process with these themes in mind can help to keep the "big
picture" in view: the planning process and even the  plan itself are toth means to. an end.
The test of successful planning is whether it improves a community's ability to prevent and
respond to water supply disruptions.

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                                                                            Page 10
                                    Exhibit 1-3
                  OVERVIEW OF THE LOCAL PLANNING PROCESS
 Identifying the
 Team Leader
 (Section 1.2)
  Forming the
 Planning Team
 (Section 1.1)
                                  Identifying Planning
                                      Priorities
                                    (Section 1.3)
ORGANIZING THE LOCAL.!
  PLANNING PROCESS
       (Chapter 1)
  Focusing on
  Key Themes
  (Section 2.1)
Placing the Plan
  In Context
 (Section 2.2)
   DEVELOPING THE
      LOCAL PLAN
       (Chapter 2)
                  Describing Existing
                     Conditions
                    (Section 2.3)
     Identifying AvallabteN
.•••'\   Planning Resources
       (Section 1.4)
                                             Assigning and
                                            Managing Planning
                                             Responsibilities
                                             (Section 1.6)
                                     I
                        Denning Who
                         Does What
                        (Section 2.4)
                                REVIEWING AND
                             UPDATING THE PLAN
                                   (Chapter 5)
     Building Consensus
       for the Plan
       (Section 2.6)
                                              Addressing
                                               Problems
                                             (Section 2.5)

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                                                                       Page J 2
                                THE LOCAL RESPONSE

      IE April,  £9$7, a teealc occurred in a gasoline supply pipeline located
directly over a weMeld supplying water  to  Sioux Falls,  South Dakota.
Although State and local governments dealt with the problem promptly, the
process showed a need jfor improved efficiency and coordination to streamline
the response time and procedures.  A  local legislative representative was
instrumental m focusing attention on the need for development of contingency
plans for Sioux Balls,  This official  was able to convince the appropriate
municipal program offices (e.g., Health Department, Fire and Rescue, Civil
Defense, etc.) that development of  a contingency plan should be an integral
'part of the city*s overall emergency  preparedness program.

Lessons learned;  Even, in the face of & real threat to public drinking water
supplies from a contamination accident, the response process often can be slow
and difficult to orchestrate without significant support at the local level.


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                                                                              Page 13
 CHAPTER 1:  ORGANIZING THE LOCAL PLANNING PROCESS
      Starting the contingency planning process for public water supplies in the right way
will have a significant impact both on the quality of the plan itself and on the efficiency
of the process. This chapter provides specific suggestions on the key steps in organizing
a productive planning process, including forming the planning team, picking a team leader,
identifying planning priorities, identifying available planning resources, and assigning and
managing planning responsibilities.

1.1 FORMING THE LOCAL PLANNING TEAM

      The State Wellhead Protection Program may identify the local entity responsible for
beginning the water supply contingency planning process. The process may be initiated by
a single individual, an agency, or perhaps a water utility.  However  it begins, contingency
planning generally grows best  out of a process coordinated by a team because:

      •     Effective response to an emergency requires coordination of many
           agencies, organizations, and individuals;

      •     Broad participation helps ensure that advantage is taken of all
           relevant and available local and State expertise and resources;

      •     Organizations and individuals that would respond to a local supply
           disruption can help to ensure that the plan effectively meshes the
           operating procedures and needs of each; and

      •     Involvement in the planning process also helps to give participants
           a sense of "ownership" in  the plan, increasing the chances that the
           plan will be used when water supplies are threatened.

Although it is unlikely the States will have sufficient resources to actively participate in a
large number of local planning efforts, local planners should take the initiative and seek
active State involvement. Even if it cannot appoint a participant  to the local planning
team, the State might be able to offer a variety of resources to assist the  local effort (e.g.,
outreach information,  technical assistance documents, partial  participation in planning
efforts).
I
LOCAL
                                                  IB ESSENTIAL
           lix Tucson/ Arizona, the various water providers were very reluctant to
      spetts time and resources to develop a contirtgency plan.  The sntalteT water
      companies couldn't see any potential tsenefit for themselves, a$ tfie major
      company felt a plan was unnecessary because it had always been able to handle
      supply interruptions with- relatively little disruption or outside assistance, Pima
      Association of Qovernments was able to illustrate the potential benefits of a
      contingency' plan for all water providers; pool the resources, knowledge,, and
      expertise of all the companies; and facilitate the development of the area's first
      water supply contingency plaru

      Lessons learned:  Without strong local  leadership, she development of a.
      contingency plan is difficult.


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                                                                              Page 14
      Exhibit 1-4 provides a list of the types of local agencies and community interests that
might be represented on a contingency planning team. It may also be helpful to think in
terms of the specific planning roles or types of expertise that will be needed.  Some
examples of important roles include:  elected official, water systems expert, hydrologist,
water quality planner, city manager or  planner, emergency response planner, emergency
responder,  response  equipment  supplier, response  contractor,  public safety  and  law
enforcement expert, public health expert, industry liaison, consumer/citizen liaison, and legal
adviser.

      When selecting team members, organizers of a local contingency planning effort
should keep three considerations in mind:

      •    The members of the group must have the ability, commitment,
           authority, and resources to  get the job done;

      •    The group must possess, or have ready access to, a wide range  of
           expertise concerning  the community, its water system and  water
           users, and the mechanics of response to supply disruptions; and

      •    The members of the group must agree on their purpose and be
           able to work cooperatively with one another.

      The  membership of such a  team  naturally will vary depending on the size  and
characteristics of each community.  In smaller communities, relatively few individuals may
play different planning roles. In veiy large communities, a planning team representative
of all affected interests might be so large as to be unwieldy.  It may be appropriate in such
cases to divide the team into subcommittees, each responsible for specific parts of the plan,
and/or  to  designate an  "executive committee" responsible  for  making  key decisions
efficiently based on team input.  In communities with relatively sophisticated water supply
agencies,  the planning  team may  actually serve as an advisory  body reviewing  and
commenting on a plan developed by the agency and/or its consultants.  Regardless of the
specific situation in a particular community, the basic goal should be to provide for broad
community participation  in the planning process  in the way that best  meets community
circumstances and needs.

1.2  IDENTIFYING THE TEAM LEADER

      Forming  an appropriate  planning team is  not  enough  to ensure success in
contingency planning.  The selection of an effective team leader can be  critical in keeping
the process on track, making sure that  all legitimate community interests have a voice in
the process, and ensuring that the planning effort is brought to completion.

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                                                                        Page 15
                                 Exhibit 1-4

POTENTIAL MEMBERS OF A LOCAL WHP CONTINGENCY PLANNING TEAM
   Mayor/city   manager    (or
   representative)

   County executive (or representative)

   City/county council members

   City/county legal counsel

   Municipal  water   authority   or
   department

   Public works department

   Water quality management agency

   Planning department

   Environmental agency

   Health department

   Fire department

   Police or public safety department

   "Hazmat" or  civil defense units

   Hospitals and medical community

   Local    Emergency   Planning
   Committee (LEPC) member(s)

   Water suppliers)

   Red  Cross  and  other volunteer
   response groups
Industry representatives (chamber of
commerce, large water users)

Community groups (environmental
groups, League of Women Voters)

Technical   experts   (hydrologists,
engineers)

Water quality laboratories

Equipment and response contractors

Media representatives

Representatives   of   neighboring
communities

State  agency  representatives (e.g.,
water and health departments)

Regional agency representatives (e.g.,
council  of governments,  regional
planning agency)

Federal agencies (e.g., EPA, FEMA,
National Guard),  including land
management  agencies who  have
WHPA's located on their lands (e.g.,
DOD, USDA, DOT)

Emergency response team member(s)

A neutral meeting facilitator

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                                                                             Page 16
                COORDINATING MUNICIPAL RESPONSIBILITIES

           When faced with the State's requirement that all public water suppliers
     develop emergency operating plans, tiie Jackson Utilities District (JUD) in
     Jackson, Tennessee, found that there was no central information source On the
     water distribution system and its components. Nor was there a map illustrating
     specific features of  the  system'or  its extensiveness.   Although  the  city
     maintained extensive hydrogeologic data on existing wellfields, there was no
     focal point for coordinating existing municipal emergency response plans to
     deal with large-scale water" service interruptions.  The contingency  plan the
     JUJ> developed in response to the State requirement is organized to provide
     detailed resource Information for those responsible for responding  to- water
     supply emergencies.  The Itlb assumed the responsibility for managing the
     development of the plan and, with strong leadership and adequate staff support,
     produced the entire plan in a few month's time,
                      '•'-..'   ;,     '"£'•..,            •• \
     Lessons leamedt  Access to extensive technical data alone is not enough to
     ensure" adequate response to witer-service  emergencies.  Existing municipal
     emergency response  plans  must  be coordinated to ensure that individual
     responsibilities are rnet during emergencies,         ,                      :
      The choice of team leader  in some cases may be obvious.   A  strong and well-
respected water department manager, for example, may be the logical candidate.  The city
manager or an elected official, or a representative of another local agency ~ public works,
public safety, or public health, for example --may be the instinctive choice.  When the
answer is not so  clear, however, the  selection process  can be made easier by  using
systematic criteria.   Several key  characteristics  might be kept in mind in evaluating
candidates:

      •    The respect of the groups represented on the planning  team;

      •    Planning experience and knowledge of the local water system;

      •    Authority  to  access  personnel, funding, and other  resources
           necessary to the planning effort;

      •    Commitment to the objectives of the planning process;

      •    Availability of time;

      •    Strong management and communications  capabilities; and

      •    Willingness to listen to the opinions of others and work to find
           consensus among diverse interests.

      In some cases, the "logical" choice for leader, based upon that person's official role,
may not be  the best  choice.   The key  point is that personal as well  as institutional
considerations should be weighed in selecting the team leader.  For example, a particular
agency may appear to have all the necessary resources for a successful contingency planning
project.  But if the person in charge of that organization does not interact well with other
local officials and community interests, it might be advisable to look elsewhere for a leader.
In any case, the team leader should be  granted the authority necessary  to perform his  or

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                                                                              Page 17
 her duties, whether that authority must be delegated by the mayor/city manager, granted
 by the town council or board of supervisors, or established as a mutual agreement by
 participating agencies.
                 INSTITUTIONALIZING THE PLANNING PROCESS

                 process of developing a contingency  plan for Oakley, Kansas,
      currently is on hold because the lead role in the process is being transferred
      from the mayor to the new City Administrator,  The planning process will mot
      be resumed until  the  new City Administrator  has become familiar with the
      essential facts of the plan and new  members of the town  council have been
      briefed on the plan's long-term benefits.  Once contingency planning becomes
      accepted as an. important component of the  city's governmental role, the
      planning process itself will become part of the government's routine activities.

      Lessons  learned:  Institutionalising the contingency planning process in a local
      government's  operations  assures continuation of the .process  and  smooth
      transitions during staff changes.

 1.3  IDENTIFYING PLANNING PRIORITIES

      Contingency planning can be a very time-consuming and expensive undertaking unless
 it is carefully managed.  The objective,  particularly for  those  communities with thinly-
 stretched municipal budgets, is to develop a "lean and mean" plan that meets local needs
 as efficiently as possible.

      A useful first step toward this goal is for the planning team, from their very first
 meeting, to begin identifying local planning priorities and targeting their efforts directly at
.those priorities.  The planning team needs at all times to remember that the objective is
 to develop a workable  plan  for responding to water supply disruptions.  All available
 information necessary to meet that objective should be obtained; additional information,
 while perhaps relevant and useful in refining and expanding the plan, should receive a
 much lower priority or be deferred to the later plan review and update phase.

      The planning team can make it easier to keep this "big picture" in view by making
 a preliminary  list of key planning considerations at one  of their earliest meetings.  Key
 considerations might include:

            •     Principal water system  features;

            •     Principal disruption threats  (including  both  contamination
                  and service interruptions);

            •     Most obvious water supply alternatives;

            •     Most readily accessible financial resources; and

            •     Leading response agencies and resources.
      This list can help target the subsequent information gathering process and can, as
 suggested by that information, be revised and expanded throughout the planning process.

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                                                                      Page 18
                                                                             Page 20
                Assessing potential water supply replacement options

                Identifying logistical  and  other  support resources to be
                employed in  response actions

     •     Water Quality/Environmental Official

                Identifying   potential   contamination  and   other
                disruption threats

     •     Local (City/County) Official

                Identifying financial  resources to  pay for response
                actions

     •     Planning/Emergency Response Official

                Determining key response procedures

                 Identifying steps that can be taken to prevent and
                 mitigate the severity of water supply disruptions

                 Developing a program for educating the public about
                 the water system and the contingency plan

                 Organizing a process for reviewing and updating the
                 plan

     The first step in assigning these tasks to members of the planning team is to match
as closely as possible member's  expertise with the  subject matter of each task.   Once
planning tasks have been assigned, it becomes the team leader's responsibility to manage
the work of team members so that it is completed on time, is  of acceptable quality, and
meshes effectively with the work of other members. Ultimately, monitoring and managing
the work of the planning team needs to be  done by  the team as a whole, operating on a
consensus basis.  This is particularly important for ensuring coherency and consistency
among the various pieces of the plan. In the early stages of the planning process, however,
it generally falls to the team leader to monitor members' progress and keep the project on
track.

      Planning meetings can  be an effective  tool if they are  used properly.  They are
particularly useful as a periodic means of  making sure that the various components  of the
plan are developing in a consistent direction.  Often, however,  meetings do not make the
best use of available time.  It is  easy for  members of a planning team  drawn from many
agencies and interests to address tangential issues  or to use team meetings as a forum for
expressing differences and grievances fueled by longstanding interagency rivalries.  Planning
meetings, therefore, should be kept to a minimum and should be highly focused. It is the
leader's  job to know when it is necessary for the group to meet, to develop a focused
meeting agenda, and to make sure that meeting discussions stick to the agenda and are
productive.

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                                                                              Pass 21
           CHAPTER 2;  DEVELOPING THE LOCAL PLAN
      Once a community's contingency planning team is  in place,  the  real challenge of
contingency planning begins,  this chapter aims to make the job of writing a water supply
disruption contingency plan easier by providing specific suggestions that local planners can
follow.  The chapter starts with a discussion of key general planning themes in Section 2.1.
The next several sections are organized according to how a local  contingency plan might
be organized:

      •    Section 2.2 describes what the introduction to a local plan might
           look like;

      •    Section  2.3 reviews  the  types  of  background information  and
           analysis associated with plan development;

      •    Section 2.4 describes how emergency response procedures might be
           developed and used; and

      •    Section 2.5 describes how a plan might incorporate identification
           of future steps that a community might take to reduce the chances
           for a water supply  disruption and to improve their readiness for
           those disruptions that do  occur.

Finally, Section 2.6 describes the process of building a broad consensus in support of the
plan.

      Note that although the identification of appropriate emergency response procedures
comes mid-way through  the  contingency planning  process,  the  emergency  response
procedures represent the relevant part of the plan during a supply  disruption event.  In
order to facilitate the use of these procedures during  an event, therefore, planners might
want to  highlight  their placement  in  the plan  (i.e.,  with colored paper or the use of
indexed tabs) or bind the entire response section separately from the rest of the plan.

      Exhibit 2-1 provides an example table of contents for a local community's water
supply contingency plan.  Although local planners clearly need to tailor this "prototypical"
plan to their own community's needs and circumstances, it provides a framework that may
make the planning process easier and more focused on the end product. Chapter 2 in
general follows this framework.

2.1    FOCUSING ON KEY THEMES

      In developing the contingency plan, the planning committee should keep several key
themes in mind:

      •     Simple  structure  and clear language are essential because  the
           primary purpose of the plan is to provide vital information and
           guidance to response personnel during or immediately following a
           water supply disruption.

      o     Tailoring a plan's structure to meet local threats and conditions is
           also important.  Planners should not waste a lot of time or fill the
           plan with extensive material addressing threats or problems that do
           not realistically face their  community.

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                                                                          Page 22
                                   Exhibit 2-1

                     ILLUSTRATIVE TABLE OF CONTENTS
                      FOR A LOCAL CONTINGENCY PLAN
Part 1:  Introduction
     Directory of Information
     Legal Authority for the Plan
     Objectives of the Plan
     Overview of the Local  Wellhead Protection Program
     Summary of Local Planning Needs
     How the Plan was Developed
     Relationship of Plan to Other Planning Efforts
     Plan Distribution
     Procedures for Review and Update
     Amendments and Changes (with Dates)

Part 2:  Background Information
     Water System Characteristics
           System Characteristics
           Use Characteristics
     Potential Sources of Water Supply  Contamination or Disruption
           Vulnerability of System to Contamination
           Other Sources of System Vulnerability
     Water Supply Replacement Alternatives
           Emergency/Short-Term  Replacement Alternatives
           Long-Term Replacement Alternatives
     Logistical Support Resources
           Personnel and Technical Resources
           Equipment and Materials Resources
     Financial Resources

Part 3:  Water Supply Disruption Response Procedures
      Emergency Identification
      Notification Roster
      Overview of Direction and Control
      Internal Communications Procedures
      Public Communications/Community Relations
      Ongoing Incident Assessment
      Contamination Containment
      Special Procedures for Non-Contamination Emergencies
      Obtaining Alternative/Supplementary Water Supplies
      Water-Use Restrictions

Part 4: Future Steps to be Taken
      Action Steps  to Prevent/Mitigate Emergency Impacts
      Training Local Responders
      Educating the Public
      Reviewing and Updating the Plan

Appendices

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                                                                                Page 23
       «    The more "user friendly" a plan is, the more likely it will actually
            be used  during  an emergency.   For example, the  plan  might
            provide removable pages that can be pasted on a wall for quick
            access, make extensive use of exhibits, place detailed information
            in a  separate  volume  so  that  it is  not  in  the way  during an
            emergency, and use a loose-leaf format to facilitate the use and
            updating  of the plan.

       •    In the plan development process, planning team members should
            take maximum use of all available technical expertise.

       By starting  out  with  these key themes in mind, planners should be able to develop
 effective and useful contingency plans.  The remainder  of this chapter presents the various
 components of a  typical water supply contingency plan and offers some guidance on how
 to develop and use such a  plan.

 2.2   PLACING THE PLAN  IN CONTEXT WITH AN "INTRODUCTION"

       The first section of a contingency plan typically will be an introduction designed to
 serve two purposes. First,  the introduction should place the plan in context by providing
 a brief review of the  origins and  objectives of the plan,  as  well as explaining the
 relationship of the plan to other State and local planning efforts. Second, the introduction
 should provide guidance on  how the plan itself should be used during a water supply
 emergency. In order  to serve both  of these purposes, the introduction to a plan  might
 consist of a number of subsections, which are described below.

 Directory of Information

      A useful piece  of information to place at the very beginning of the  plan is  a
 "Directory of  Information."  Similar  to an annotated table of contents, the purpose of a
 directory is to identify both the various plan sections relevant for undertaking a particular
 response action and the locations of those sections in the plan. Such a  directory can be
 particularly useful if it notes the different techniques used to highlight important sections
 (for example,  "all  response  procedures are printed on colored paper and subdivided with
 tabs").  This subsection also  might facilitate  plan use  if it includes an exhibit providing
 definitions of any abbreviations, acronyms, and key terms used in  the plan.  Finally, this
 subsection might conclude with a succinct statement (i.e. about one paragraph) of when
 and how the plan should be used.

 Legal Authority for the Plan

      This subsection  would summarize State requirements, local actions, agency-specific
 responsibilities relevant to the plan,  and the  division of funding responsibilities for plan
 development (for  example,  from general funds or by  agency).  This discussion will be
 particularly useful to parties reviewing and updating the plan in the future by helping to
 explain why particular approaches or response procedures were adopted for the plan.  It
 might be helpful also to include an appendix containing the full legal documentation (for
 example, city  council  resolutions or  State legislation or regulations) referenced in this
 section of the plan.

 Objectives of the Plan

      The introduction should contain  a clear statement of the objective(s) the plan  is
designed to meet, such as  specific contingencies  that are addressed and the types of
response procedures that are set out.  In addition to improving response capabilities, plan

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                                                                              Page 24
objectives might include educating the public and providing orientation for training new
water system personnel.
                                     VER&CTIOC wwmM?" "'    v
                          ""  -v ,           "<"•&?          **&*<>    f v / y-<'^f  '',  *
                             ' ">    •*       f '-.           $••-   .,       _      *  <•  ••
           Jackson, Tennessee, sees' its contingency plan as' both a  manWl  tor
      responding to water supply emergencies'and an educatiohaVtraining resource
      for new employees, iking the newly Developed plan, new employees cam feara
      about  Jackson's  entire  water'supply  system*  inetediag  the locaiioa and
      specifications of its components, alternative supply response procedures, anil
      the roles of Individual mnnpipal sectors (e.g., fire, jeescue, civil defense,, etc.)
      in copin&with a watei service emergency,' The plan also distinguishes betweiea
      Internal   fesoiirees   
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                                                                              Page 15
 Plan Distribution

      The process by which official copies  of the plan have been distributed is typically
 shown by providing a "distribution list" exhibit.  Copies of the plan should be provided to
 all key response personnel and other public officials, and should be made accessible to the
 general public (for example, at a public library).

 Procedures for Review and Update

      A brief summary of the procedures for reviewing and updating the plan should be
 provided in the introduction.  The summary should identify the parties responsible for
 maintaining the plan, note the frequency with which the plan will be routinely updated, and
 briefly describe how the plan testing and review process will work.   This section of the
 introduction should highlight the importance of keeping the plan current and up-to-date.

 Amendments and Changes (with Dates)

      In addition to providing a list of all parties holding an official copy of the plan, the
 introduction might provide a sheet for recording any amendments or other changes to the
 plan, along with the date of those changes.   This is  particularly important for changes in
 response procedures  and notification telephone numbers.    Plan  changes should be
 distributed to all holders of official copies (those on the distribution list mentioned above)
 in order to ensure that everyone has the  same understanding of appropriate response
 procedures.

 2.3   DESCRIBING EXISTING CONDITIONS - BACKGROUND INFORMATION

      The planning team should review the physical attributes of their water supply system
 and identify the local resources (personnel, equipment, logistics, and finances) that will be
 necessary to make the plan work.   By taking the time to familiarize themselves with the
 vulnerabilities of their system and local response capabilities, water supply  planners can
 take steps to prevent a water supply disruption from becoming a water supply emergency.

      A  background review and analysis of the  local water supply situation also will help
 planners evaluate their contingency planning status and determine what needs to go  into
 their plan. Although the level of appropriate detail will vary, specific planning factors that
 should be considered by all planners include:

      •     Water system characteristics;

      •     Potential sources of water supply disruption;

      •     Water supply replacement alternatives;

      •     Logistical support resources; and

      •     Financial resources.

It  is especially important  that the  information used  in  the  background section  be as
complete and current as possible.   The use of outdated information, especially inaccurate
maps, can seriously limit the value and utility of the plan.

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                                                                             Page 26
Water System Characteristics

      The most important component of any water supply plan is the physical process of
getting water from a source to the customer.  Water supply planners need to familiarize
themselves with both the mechanics of the system  and the needs of their customers in
order to determine appropriate methods to ensure that the flow of water is not interrupted.
Much of  the  analysis  of the  system will go  on "behind the scenes" and need not be
incorporated into the contingency plan itself, although the fact that the analysis was done
should be documented in the plan.   Much of this information will be  available  in the
community master plan or from the water department.  The  planning process can be a
convenient means of gathering the relevant information in one place, or updating records
if a central agency has not already undertaken these steps.

      The plan should include basic water supply information  such as:

      •     Location arid capacity of individual wells and storage tanks;

      •     Location and capacity of water treatment facilities;

      •     Location and capacity of major distribution lines; and

      •     Key points for isolating sections of the  system.

The water use characteristics  of the  communities that are being served also should be
determined  because such information can be critical in determining whose needs must be'
met first in the event  of a supply disruption.  Both capacity  and water use information
should be recorded using common measures such as maximum and average gallons per day.

      The water system  can be characterized in a  single schematic  of the water supply
system (see Exhibit 2-2 for an example), as well as with tables or charts which illustrate the
major uses and users of water in the community.  If this information is readily available
through other sources (for example, the water supply master plan  or utility files), the
contingency plan can simply reference the specific location where the records are located.
All such information should be conspicuously dated.   Exhibit 2-3 indicates some of the
factors that should be analyzed when reviewing these components of a ground-water supply
system. Operators of water supply systems that rely on one or  more surface water sources
(e.g., reservoirs, lakes, rivers)  in  addition to wells should note the use of those sources,
along with water quantity and quality information.

Potential  Sources of Water Supply Disruption

      Tailoring a plan to community conditions and needs is  one of the most important
challenges facing the  planning team.  Accurately identifying  the most  likely disruption
threats to the water supply is the best place to start this process.

      Short-Term Versus Long-Term Disruption Events

      As  a  general rule, water supply contingency plans are designed to meet immediate
or near-term  contingencies. A power outage, vandalism, a hazardous substance spill, and
sabotage are  all examples of such 'Contingencies. While longer-term problems, such as a
prolonged drought or a plume of contamination not expected to reach a wellfield for many
years, are very important, they are more  relevant to long-term  water supply planning than
contingency planning.  To the extent that contingency plans address long-term problems,
they should be given less emphasis than more immediate threats.

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                                         Page 27
         Exhibit 2-2
EXAMPLE OF A SCHEMATIC DIAGRAM
 3£=
  V®
             Ta
&
Vc
                                 rUa
Ub
                                 LUC
                             Vd
                                       rUd
                              Key:
                              W = Wall and Pump
                              T s Treatment Facility
                              V = Valve
                              UsUser

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                                                                                    Page 28
                                     Exhibit 2-3

           REVIEWING WATER SYSTEM COMPONENTS -- KEY FACTORS
                                 Supply Components

      The supply component of the water supply system consists of the supply wells and the
facilities for delivering the water to the treatment plant (if any). Each well should be analyzed
for three major factors:

      1)    production capacity;
      2)    connection to supply; and
      3)    monitoring wells.*

For each of these factors,  consider the following questions:

      1)    Production Capacity (supply wells)
                   What  is the  maximum yield?
                   What  is the  pump capacity?
                   What  is the  current flow?
                   Are there seasonal variations?
                   Is there excess capacity?

      2)     Connection to Supply (pumps, valves)
             •     Can the well be  isolated or cut-off?
             •     Where is the pump cut-off?
             •     If the well is cut-off, what are the impacts on supply?
             •     How can supplies be obtained from another system?

       3)     Monitoring Wells
             •     What are the potential sources of contamination in the wellhead
                   area?
             •     Are  monitoring wells located  to  detect contamination from
                   identified potential  sources?
             •     Are  well samples  and monitoring  well  samples analyzed for
                   contaminants from  potential sources?            •
       Note that while monitoring wells are a part of the supply system, they usually do not
       have production capacity and are not physically connected to the water-supply system.
       Monitoring  wells  should  be evaluated to  assess  their  suitability  for  detecting
       contamination.

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                               Exhibit 2-3 (continued)

           REVIEWING WATER SYSTEM COMPONENTS -- KEY FACTORS
                               Treatment Components

      The second component of the water supply system consists of the treatment facilities
and processes, which should be analyzed to determine:

      1)    treatment process capacity;
      2)    types of contaminants treated; and.
      3)    impact of contamination on treatment capability.

For each of these elements, consider the following questions:

      1)    Treatment Process Capacity
            •     What is the maximum volume of water that can be treated?
            •     What is the current flow?
            •     Is there excess treatment capacity?
            •     Can the existing treatment process be expanded or modified?

      2)    Types of Contaminants Treated
            •     What contaminants can be treated?
            •     How are they identified?
            •     How does treatment capacity vary by type of contamination?

      3)    Impact on Treatment Capability                            '
            •     What levels of contamination will exceed the existing treatment
                  system's capacity?
            •     What type of contamination would impair the system's capability
                  or otherwise pass through?

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                                                                                     Page 30
                                Exhibit 2-3 (continued)

           REVIEWING WATER SYSTEM COMPONENTS -- KEY FACTORS
                               Distribution Components

      The third component of the water supply system is the distribution network, which has
three primary parts: 1) the distribution pipes and connections, 2) system operating procedures,
and 3) storage capacity. Careful analysis of the distribution system is essential because it may
be vulnerable to contamination and will also influence the selection of appropriate supply
replacement options.  The analysis will be easier if current maps or system schematics can be
used. The analysis should answer the following questions:

      1)     Distribution Pipes and Valves
                   What is the maximum flow capacity?
                   What is the current flow?
                   Is there excess capacity?
                   How does water pressure affect distribution?
                   What portions of the pipe system are vulnerable to contamination?
                   Are there alternative distribution routes?

      2)     Operating Procedures
             «     What portions of the system can  be isolated or  shut-off in the
                   event of contamination?
             o     If portions of the system are shut-off, what are the impacts?
             •     What adjustments would have to be made to utilize an alternative
                   supply source?

      3)     Storage Capacity
             •     What  is  the  system  storage  capacity?   Are  there  seasonal
                   fluctuations?
             •     Is stored water vulnerable to contamination?
             •     Is there an alternative supply source available that could be stored?
             •     How can stored water be treated and distributed?

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                                                                                       Page 31
                                Exhibit 2-3 (continued)

           REVIEWING WATER SYSTEM COMPONENTS - KEY FACTORS
                          Analysis of Water Use and Demand

      A detailed knowledge of water use and demand is necessary in order to plan for water
supply replacement.  In order to  choose the best alternative, planners must know the existing
levels of use and the demand of different sectors of the community.  The analysis of water use
and demand should:

      1)     establish  maximum daily consumption levels;
      2)     establish  minimum daily consumption  levels; and
      3)     identify priority uses.

      The following steps might be followed to determine demands on the system for drinking
water and other purposes:

      1.     Estimate  present and projected water use (particularly for  major,  if  not
             all, users):
             a.     Record average daily consumption, minimum daily consumption,
                   and  maximum  daily consumption  levels by  use category.   If
                   appropriate, major users for each category might be identified. Use
                   categories include:
                         residential;
                         commercial;
                         industrial;
                         institutional;
                         fire safety; and
                         agricultural.
             b.     Project daily use over,  for example, 1,  2, and 5 years.   Note
                   seasonal fluctuations, if any.  Projections allow the contingency
                   plan to reflect future conditions, especially regarding the siting and
                   planning for new wells.          •
             c.     Revise projections to take into  account population increases and
                   changes in commercial and industrial development.

      2.     Determine priority uses:
             a.     High priority uses for public health protection may  include:
                   •     household and other public drinking water supplies;
                   •     hospital supplies; and
                   •     fire fighting systems.
             b.     Lower priority uses may include:
                   •     landscaping;
                   •     certain industrial processes; and
                   •     non-essential household uses.

      3.     Determine the supply requirements for priority uses including:
                   •     minimum quantity;
                   •     minimum pressure levels;
                   •     time of supply; and
                   •     quality of the supply.

      If the water supply system is large enough, this information might be more useful if
organized by  geographic area.

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                                                                                Page 32
        Specific contingencies will vary from community to community depending on many
  factors,  such  as  hydrologic  conditions, local land  uses  and  sources  of  potential
  contamination, and characteristics of the water supply and distribution network. Examining
  the historical record provides one useful source of  information about  likely disruption
  threats.  Problems that have occurred in the past, such as droughts and floods, may occur
  again.  The longer the period of time for which such information is available,  the more
  reliable it is for projecting conditions.

        Disruption Events Resulting from Contamination

        Planners should pay special attention to potential sources of chemical contamination
  arising from chemical transportation, storage, and use patterns. A contamination event of
  particular concern for emergency planning purposes might  entail the contamination of a
  specific wellfield or the wide-spread contamination of an aquifer that poses a near-term
  threat to a wellfield.  Localities with ground-water supplies that  are  hydrogeologically
  vulnerable,  especially those formations characterized  as karst terrains, should pay special
  attention to the potential for contamination.  Karst terrains, defined as limestone and
  dolomite formations subject to rock dissolution, are particularly vulnerable to contamination
  because of the rapid flow of ground water and, hence, contaminants.

        Under the SDWA, State Wellhead Protection Programs must identify anthropogenic
  sources of contamination within Wellhead Protection Areas. The information collected in
  conjunction with the State's source identification  efforts could be useful to  localities in
  their contingency planning  efforts.  Moreover,  studies done by public water suppliers to
  meet the SDWA volatile organic chemical (VOC) monitoring and vulnerability assessment
  requirements will yield information on potential  contaminant sources.  Appendix E, a
  hazardous spill vulnerability checklist, reviews potential sources  of hazardous  materials
  contamination.  Appendix F provides an overview of different types of hazardous materials
  regulated under Federal environmental programs.                   ,

         Exhibit 2-42 presents a list of potential sources of contamination.  Although all of
  these will not be of concern to every community, the  list presents a starting  point for
  planners in reviewing threats to their  ground water.  The list provided in Exhibit 2-4  can
  be a very useful tool in conducting  what is often called a "windshield survey."  Using the
  list and an appropriately-scaled map, several planning team  members can drive around the
  area surrounding public wellfields  and  known ground-water recharge  areas identifying
  businesses that may pose a contamination threat. Examples  might include gasoline stations
   (and other businesses with underground storage tanks), autobody and metal working shops,
  and dry cleaning plants.
2 Sources used to compile Exhibit 2-4 include:

         Hrezo, Margaret and Nickinson, Pat, "Protecting Virginia's Groundwater:  A Handbook
              for Local Government Officials," Virginia Watef Resources Research Center and Virginia
              Polytechnic Institute  and State University, November 1986;  .
         Jaffe, Martin and DiNovo,  Frank, Local Grbundwater Protection, the American Planning
              Association, Chicago, Illinois, 1987;
         Page, William E.,  ed.,  Planning for Groundwater Protection, Academic Press,
         Inc.,
              Boston, MA, 1987; and                                                           ;
         U.S. Environmental Protection Agency, "Wellhead Protection Programs: Tools
         for  Local
              Governments," EPA  440/6-89-002, April 1989, Office of  Water, Washington, D.C.

-------
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-------
                                                                                                   Page 34
                          Other sources of assistance might  include local land use planners and planning
                    students from local universities who can play a part in identifying potentially contaminating
                    land  uses, and the  community's local emergency planning committee (LEPC).  LEPCs,
                    potentially very rich sources of information, are among the custodians of key emergency
                    planning and community right-to-know information that industries, transporters, and farmers
                    must report under Title III of SARA.  Title Ill's reporting requirements include:

                          •     Section  302. which requires facilities that have present any of over
                                360  extremely  hazardous chemicals  above  a certain  threshold
                                quantity to report that fact to their LEPC for the latter's use in
                                developing a hazardous materials emergency response plan. These
                                facilities include farmers who  use many common pesticides.  The
                                plans developed by LEPCs must also identify'transportation routes
                                carrying hazardous chemicals.

                          •     Section  304. which requires facilities to notify LEPCs  whenever
                                there is  a spill of any of several hundreds extremely hazardous and
                                hazardous chemicals above a  threshold quantity.  This is a very
                                useful source  of both real-time  notification of spills  that  may
                                threaten ground  water and information  concerning chronic or
                                large-scale spillers.

                          •     'Sections 311-2. the so-called "community right-to-know" provisions
                                of Title III, which require  facilities to  provide very detailed
                                information concerning the quantity and  location of hazardous
                                chemicals  on-site, as well as health effects associated with those
                                chemicals and emergency response guidelines.

                    In addition, Section  313 of Title III requires industry to report to States and the U.S. EPA,
                    their total annual emissions  of many hazardous chemicals to all environmental media,
                    including ground water. This information  provides a useful starting point for pinpointing
                    sources of existing or future aquifer contamination.  While Title III does not apply to all
                    local facilities, or to all hazardous chemicals handled  at  such facilities, it does provide a
                    very good source of information  on potential  ground-water contaminants.   Local water
                    supply contingency planners would be well-served to contact their community's LEPC and
                    include an LEPC representative on the planning team.

                          Planners in localities with  concentrated activities that might pose  a threat of
                    contamination to ground water supplies (such as agriculture or mining) also might want to
                    compile a list of chemicals or other hazardous materials used for those activities  and
                    include that list  in  a  separate appendix for ease of  reference.  Such a list, along with
                    relevant characteristic  and handling information, could be  especially useful during a
                    response effort.

                          Prioritizing Potential Disruption Events

                          Each  community must decide for itself what it will  consider a threat or contingency
                    that needs to  be  addressed in its plan.  Regardless of how a community sets its priorities,
                    it may be useful to think of selecting the appropriate contingencies as a screening process.
                    The planning team first identifies a variety of possible contingencies and then screens these
                    contingencies  to assess their importance. Exhibit 2-5 presents one format that can be used
                    for evaluating potential threats by assigning estimates for both probability and severity.
                    Those threats with  a  high probability  are more likely to occur, while those with high
                    severity will have more of an effect on the water system. As an alternative, a third column
.

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                                                                                      Page 35
                                        Exhibit 2-5

                EXAMPLE OF EMERGENCY PROBABILITY AND SEVERITY CHART

TYPE OF EMERGENCY
Natural:
Drought
Flood
Ice/Snow Storm
Wind
Earthquake
Hurricane
Forest Fires
Man-Made:
Fire
Explosion
Chemical Contamination
Vandalism
Riots
Strikes
Sabotage
Power Outage
Poor Operation/Maintenance
Probability
10-High 1-Low

10
7
1
5
1
1
1

6
6
5
10
2
1
10
8
2
Severity
10-High 1-Low

10
5
1
. . 5
1
1
1

4
5
5
10
1
1
5
7
2
                                                                    REMARKS
                                                                Seasonal only
                                                                 Currently a problem
                                                                 Increasingly a concern
Source:    The format for this chart was adapted from "Emergency Planning and Response - A Water
          Supply Guide for the Suppliers of Water," New York State Department of Health, January
          1984); the data reflect emergency probabilities for the City of Tucson, Arizona.

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                                                                               Page 36
could be added to the chart in Exhibit 2-5 that would include an overall "weighting" factor,
combining probability and severity.

      Whatever method or  format is  Tased, the  screening  of a large set of potential
contingencies should yield a  smaller set of "primary" contingencies.  These threats would
then receive the most urgent attention in the planning process; other threats would either
receive less detailed consideration or be deferred entirely to a later plan review and update
process.

      Once the planning team has selected an initial or priority set of supply disruption
contingencies, these threats  must be  summarized in  a way  that is useful in designing
appropriate  response actions.  One of the most  effective ways of  capturing  threats for
planning purposes is to write likely water supply  disruption scenarios  that  summarize
situations in brief, narrative form.  The best way to illustrate this technique is by example:

      Scenario  1  — Underground Pipeline Break:  In April 1987, Sioux Falls, South
      Dakota experienced a break  in an underground gasoline transmission pipeline
      which occurred within a half mile  of the City's major  public water supply.
      Although the  break was discovered by chance early  on and the  pipeline
      company worked swiftly  with the  South  Dakota  Department of Natural
      Resources  and the  City of Sioux Falls to correct the problem,  the incident
      demonstrated the potential for extensive  ground-water contamination.

      Scenario  2 - Agricultural Activities:  With agriculture the primary activity in
      and around Oakley, Kansas, several potential pathways of  ground-water
      pollution are possible.   Agricultural chemicals (pesticides and fertilizers) are
      used heavily throughout  the area  and  contribute a well-defined  subset of
      potential contaminants to ground-water reserves in the area.  Above-ground
      and underground storage tanks containing petroleum products are numerous
      in  the area and have  maintenance histories of varying  reliability.  Grain
      elevators in the immediate area are a potential source of VOC contamination
      from fumigation activities connected with cereal grain storage.

The key elements of planning scenarios can be seen in these examples ~ a brief  description
of the event triggering a supply  disruption, perhaps  a few facts  or other events that
complicate matters, and a  summary of the immediate water supply implications.

      It is most important to develop scenarios for those disruption threats considered as
priorities for planning purposes.  If there are numerous priority threats,  however, it may
not be necessary to capture all of them in scenario form.  Many emergencies will involve
similar response  procedures.  Within the set of priority threats planners should develop a
variety of scenarios that will require use of different response equipment, personnel, and
procedures (for example, contamination in the  wellhead area, well collapse, line break, or
power loss)  to  allow development of different response approaches.

      The plan should contain a list of potential threats, possibly identified in a schematic
that overlays the supply system.  This list can be updated,  as needed, to help maintain
discussion of prevention and mitigation steps in a current list of priorities for preventive
measures and response needs (see  discussion of prevention and mitigation steps in Section
2.6 below).   The plan should also provide several of the disruption scenarios  to help
members of the response  team identify appropriate responses.

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                                                                              Page 37
Water Supply Replacement Alternatives

      The primary concern of any water supplier when faced with a disruption is providing
an uncontaminated supply of water to the customer.  Depending on the nature of the
problem, an alternative source may be required for a number of hours, days,  weeks, or, in
a worst-case situation, permanently.

      As a matter of planning priority, it is important to identify appropriate  emergency
and short-term options first; these  include, respectively, the steps required for  immediate
provision of water for a period of hours or days, and those which provide an interim supply
for periods of weeks or months.  Neither of these types of actions are intended  to provide
a permanent,  or long-term solution.  The response team can then decide upon the best
alternative, based on the situation they face.

      In general,  there are five categories of alternative water supplies:

      •    Supply from within the system;

      •    Supply from outside the system;

      •    Modification or reduction of water use;

      •  ,  Water supply treatment; and

      •    Aquifer remediation.

      One  or  more of these supply sources may be employed depending on the specific
characteristics of the water supply system and the cause of the disruption.  Clearly, not all
of the options are viable  alternatives in every situation.  For example, remediation of
contaminated  supplies  is not possible in an emergency response because  of the time
required to put remediation technology, such as carbon filtration, in place.  Long-term
reduction of demand is probably not politically acceptable in most communities.  Exhibit
2-6 lists several specific actions within emergency, short-term,  and long-term  time frames.
Each  of these actions may relate to more than one of the five categories of supplies listed
above. Tank trucks, for instance, may be available within the system or from outside.  A
new wellfield may be possible within the system or contamination may require payment to
another system to help them construct a new wellfield. Exhibit 2-6 also briefly summarizes
several criteria that can be used to judge the viability of a particular supply replacement
option. A detailed evaluation of the  listed options can be found in Appendix  G.

      In evaluating alternative water supply replacement sources, the planning team should
rely on  the water system's  managers and staff  because  they have  the best practical
familiarity  with water use patterns and  are in  the  best position to judge the  overall
adequacy of potential  sources.  The plan itself should contain an identification of those
options that represent  the most realistic and practical  responses to the planning scenarios.
If the community has  the resources,  planners may wish to  develop  a matrix that ties
specific supply replacement alternatives to specific water-loss emergencies.

Logistical Support Resources

      One  of  the key objectives of the contingency planning process is ensuring that the
proper personnel, equipment, and technical resources are  available  in case of a water
supply disruption.  The contingency  plan itself should enable local officials and water
system managers  to rapidly identify and coordinate these resources in actual emergency
situations.  The basic components  of logistical planning include:

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                                                 Eichibit 2-6

  EMERGENCY, SHORT-TERM, AND LONG-lfERM WATER SUPPLY REPLACEMENT OPTIONS
          Emergency and Short-Term Options

    Bottled Water
    Tank Trucks
    Excess Capacity
    Conservation
    Treatment
         Point of Use
         System
•   Additional Treatment

                   Long-Term Options

    Drill New Wells/Wellfields
    Additional Treatment In-System (without cleaning up
      contaminant source)
    Point-of-Use Treatment
    Clean up contamination source
    Well Field Management
         Blending
         Select Pumping
    Interconnection
    Bottled Water
    Surface Water Supplies
    Water Conservation
    Waste-Water Reuse Reinjection
    Desalinization
    Dual-Systems
    (Separate potable/non-potable supplies)
    Artificial Aquifer/Excess Capacity
    (Seasonal storage)
                                                                Criteria for Evaluating Options

                                                    Technical and Logistical Feasibility
                                                     •   What procedures are required to implement?
                                                     •   Are technologies available and well developed?
                                                   ,  •   How much water can  it provide?
                                                     •   Can it meet the system's priority water uses?
                                                     •   Can it meet the system's total water needs?
                                                     •   How quickly can it be made operational?
                                                     •   What equipment and supplies are needed?

                                                    Reliability
                                                     •   How reliable is it?
                                                     •   Does it require operation and maintenance skills?

                                                    Political Considerations
                                                     •   What administrative procedures are required?
                                                     •   Is property ownership a problem?
                                                     •   Will it gain public confidence?             :

                                                    Cost Considerations
                                                     •   What is the initial investment?
                                                     •   • What are the operating costs?
                                                     •   Who  bears the costs?

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                                                                              Page 39
      •    Identifying key personnel; and

      •    Identifying essential services, equipment, and supplies.
Clearly  identifying logistical needs  lays a necessary foundation for the notification and
logistical coordination procedures that will govern responses to supply disruptions.

      A critical issue to keep in mind  when  structuring  this part of the plan is that
resource inventories must reflect only those resources that are currently on hand or readily
available in an emergency.  At the same time, however, the planning process may identify
logistical shortcomings.  "Wish lists" of personnel or equipment needs should be placed in
the future steps  section and  then incorporated into the backgrourid information and
response procedures sections only when they are in fact on hand.

      Personnel Needs

      The  key question in  emergency response situations  is  "who's  in  charge?"   It is
essential to have a designated response coordinator in a response situation whose role is
clearly understood by all.   This coordinator, who should be identified in the plan, must
have the expertise and authority required to coordinate all of the activities that make up
a response action.

      The response coordinator will draw upon a variety of supporting personnel to assist
in the implementation of specific response procedures. The plan should identify individuals
with expertise  in public health, water supply operations, financing, and public relations.
The people chosen to fill these roles must also have the authority to carry out the duties
delineated in the contingency plan.  It may be necessary for the local government (e.g. city
council, board of selectmen) to delegate officially certain emergency authorities to specific
individuals or,  more genetically, to representatives of specific local agencies.  A list of all
involved individuals, including names, phone numbers, addresses, and response assignments
should  be prepared, with alternative individuals designated.  Also, the chain-of-command
within and between personnel units should be defined in the plan, with scheduled updates
of the personnel list. Finally, personal ties among the key players in the response team
parties  should  be established prior  to a supply disruption; this will make coordination in
the event of an emergency much smoother.

      If there  are deficiencies in the number  of people or types  of expertise available
within the community, those needs may be met through hiring, training, arrangements with
private contractors, or cooperation with other State or .local entities through "mutual-aid"
agreements or memoranda of understanding. These arrangements should be made at the
planning stage and documented in the contingency plan (copies of mutual-aid agreements
might be placed in a plan appendix, for example).

      Services, Equipment, and Supplies

      In addition to personnel, materials and contractor services  must be identified to
enable  the implementation of response measures.  For example, a broken water line may
require replacement pipes and fittings; chemical spills may demand the use of absorbent
materials, containment booms, excavation equipment, and water quality laboratory analysis;
and a collapsed well may require rapid response from a well drilling company, which may
be located some distance away.   The  planning team  should evaluate priority supply
disruption threats with an eye towards the physical resources  and  expertise necessary to
provide an adequate response.  Once  those  resources are  identified, the contingency
planners must determine where they can  be found.

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                                                                             Page 40
      Exhibit 2-7 illustrates an example from a typical equipment list.  The capacity of the
individual pieces of equipment, although not  provided in the example, would be useful
information to include in a plan because equipment needs then could be tied more directly
to specific equipment, thus  reducing response time. A complete list of equipment and
services would be more exhaustive and include such items as:

      •     Chemical supplies;

      •     Treatment equipment;

      •     Spare parts (i.e., pipes and fittings);

      •     Alternative distribution equipment (tank trucks);

      •     Vehicles and equipment for emergency excavation and transportation;

      •     Water sampling and analysis equipment and services;

      •     Portable pumps and generators;

      •     Portable treatment  equipment;

      •     Personnel protection equipment and supplies;

      •     Repair  facilities;  and

      •     Heavy equipment contractors.

      Depending on the size of the water supply  system and whether the system is a
private company or a public utility, these resources may be found in-house or may be
available from  another branch of the municipality - for example, the  public works
department. Once resource needs have been identified, water planners should consider the
following types  of questions:

      •     If the resource  cannot be located within the municipality, is it
            available from an adjoining city or town, from the State emergency
            response office, or the National Guard?

      •     Are there local contractors who would be willing to enter into an
            agreement to provide emergency services?

      •     Where  is  the nearest well drilling firm and what sort of response
            time can they guarantee?

Response equipment and services that are identified as essential but cannot be secured at
the present time must be highlighted. Addressing this deficiency should be included in the
"Future Steps" section of the plan (see  Section 2.5 below) as a priority agenda item for
improving local response capabilities.

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                                                                                                      Page 41
                                                 Exhibit 2-7

               EXAMPLE OF LIST OF AVAILABLE WATER TREATMENT EQUIPMENT


       The following is an illustrative list of water department equipment and its location.
Quantity     	Type	

  1         Fork Lift
  4         Air Compressor
  1         Trencher
  1         Tapping Machine
  1         Earth-boring Machine
  1         (2040) Tractor
  2         Sewer Bucket Machine
  1         Concrete Mixer
  1         Welder
  1         Jet Clean Truck
  1         TV Sewer Van
  1         Ag-Gator
  1         Fork Lift
  2         580 C Backhoe
  2         580 SB Backhoe
  1         Trailer (dual)
  1         Trailer (material)
  1         Trailer (utility)
  1         Trailer (tandem)
  1         Sewer Rodding Machine
  1         Drill & Angur Assembly
  1         Drill & Augur Assembly
  1         Hydraulic Jack
  1         Hot Roll Machine
  1         Dump Trailer
  1         Pressure Water
  1         Jack Hammer
  1         Power Drive
  1         Power Drive
  1         Hydraulic Valve Operator
  1         Test Pump
  1         Gas Air Compressor
  3         Trash Pump (2 ft.)
  1         Multipurpose Saw
  3         Sewer Wagon
  1         Tapping Machine
  3         Multi-Purpose  Saw
  1         Generator (gas)
Age and
Manufacturer
1980 Caterpillar
Ingersoll-Rand
Davis
1963 Smith
NA
John Deere
NA
Stone
Hobart
1978 Chevrolet
1980 GMC
NA
1980 Clark
1978 Case
1986 Case
Hy-Power
NA
1972 Snoco
Hudson
NA
1970 Mighty Mole
1988 Mighty Mole
1963
1963
NA
1983
1980
1975 Wach
1964
1982
1984 Hydro
NA
NA
NA
NA
1987
NA
NA

Location
WW Plant
Equip. Yard
Equip. Yard
Dist. Shop
Dist. Shop
Equip. Yard
Equip. Yard
Equip. Yard
Dist. Shop
Dist. Shop
Dist. Shop
Storeroom
WW Plant
Equip. Yard
Equip. Yard
Equip. Yard
Equip. Yard
Equip. Yard
Equip. Yard
Equip. Yard
Dist. Shop
Dist. Shop
Dist. Shop
Dist. Shop
Equip. Yard
Dist. Shop
Dist. Shop
Dist. Shop
Dist. Shop
Dist. Shop
Dist. Shop
Equip. Yard
Dist. Shop
Dist. Shop
Equip. Yard
Dist. Shop
Dist. Shop
Dist. Shop
Capacity
    Name and
 Phone Number of
Qualified Operators')
 NA - Not available

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                                                                             Page 42
Financial Resources

      Provision of alternate water supplies, particularly on an emergency basis, can be a
costly proposition for many communities. In determining the level of funding necessary to
meet  these needs, the community  must look  not only  at  the  costs  associated with
responding to specific incidents, but also the costs associated with developing and updating
the contingency plan.

      In planning for  water supply needs,  communities  must first evaluate  their own
financial sources.  In this process, they should consider both traditional and  innovative
funding approaches, including property tax assessments, specialty taxes, user charges, and
short-term  and long-term borrowing.  Funds that are, or could be, available through the
community's  normal operating, capital, and  emergency  budgets  should be  identified.
Localities may need to create new contingency funds, bonding authority, or lines of credit
for emergency water supply needs.

      The lack of adequate local financial resources is often cited as a major obstacle both
to developing a formal water supply contingency plan and to responding effectively to
ground-water contamination and other types of supply disruptions. Localities might be able
to take advantage of emergency Federal or State authorities  during supply disruption in
order to secure funding for some response activities.  For example, Section 1431 of the Safe
Drinkin'g Water Act grants EPA the authority to respond to contamination events that
present an "imminent and substantial endangerment to the health of persons" and that have
not been addressed by appropriate State and  local  authorities.   In  undertaking  this
response, EPA may order the provision of alternate water supplies to affected parties by
the "persons  who caused or contributed to the endangerment."  Similar State  emergency
powers might be applied in some response actions to help defray the costs of those actions.
Nonetheless,  local officials should strive to make these contingency plans self-sufficient and
not dependent on such Federal emergency assistance.

      In addition to such emergency funding options, some Federal and State sources may
be available  to  supplement local resources for plan development and implementation.
Exhibit 2-8  presents  several of  these potential  funding sources,  along  with a  brief
description of how funds from  each might be used.  Additional  information regarding
Federal and State sources of funds can be found in Appendix H.  The contingency plan
should identify specific Federal and State programs that are currently available and (in the
response procedures section)  the  specific means of accessing the funds these programs
might provide.

2.4   DEFINING WHO DOES WHAT - EMERGENCY RESPONSE PROCEDURES

      Once the  planning team has defined the components of the water supply system,
identified the potential threats to the supply, and defined the resources necessary to ensure
that water  supply can be maintained, it  is time to establish the procedures governing and
coordinating  response activities.  Certain general procedures that should be developed and
agreed upon  beforehand include:

       •    Emergency identification;

       •    Notification of key response personnel;

       •    Incident direction and control;

       •    Internal communications;

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                                                                                    Page 43
                                     Exhibit 2-8

                  STATE AND FEDERAL FUNDING SOURCES AND
             THEIR POTENTIAL USES FOR CONTINGENCY PLANNING
         Funding Source
            Potential Use of Funds
State "Superfund" Programs
State Hazardous Material Spill Funds
State Grant Programs
Federal "Superfund" Program
Federal Leaking Underground Storage
Tank Trust Fund
Uses vary by state; typically used for remediation of
contaminated water  or  establishment of alternate
supplies.

Some states have revolving funds that can be used to
cover remedial tasks and  both direct and indirect
damages.   Some  legislation requires states to use
such  funds  to   provide  water   supplies  until
responsible parties do so.

Traditional grant programs  for public  facilities
construction, low-income housing, and community or
urban  development  can sometimes be  used for
construction  of  alternative  water  supplies  or
rehabilitation of contaminated supplies.

Funds may be provided for emergency response and
clean-up of hazardous substances through short-term
removal actions or long-term remedial actions, both
of which may include the provision of alternative
water supplies.

Trust funds  are  used  for clean-up  of  leaking
underground tanks and for provision of alternative
water supplies.  Priority situations for  funding are
those where  prompt action  is essential  or the
owner/operator of the tank(s) or facility cannot be
identified.
Farmers Home Administration Grants
Army Corps of Engineers Programs
Federal Emergency Management Agency
Funds
Housing and Urban Development Funds
Grant-loan  combinations  are  made   to   rural
municipalities  to construct or rehabilitate  public
water systems.

The Corps may supply temporary, emergency water
supplies after a contamination incident.   However,
funds cannot cover contingency plan development,
decontamination, or system repair and are meant to
be supplemental to community efforts.

Funds can be used to defray necessary and essential
civil  defense expenditures  associated  with planning
and implementation.

Grant funds are available for state and local planning
and   implementation   activities  concerning  the
provision of public services, including water supply
systems.

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                                                                              Page 44
      •    Public communications/community relations;

      •    Ongoing incident assessment;
      •    Contamination assessment;

      •    Special procedures for non-contamination events;

      •    Obtaining alternative/supplementary water supplies; and

      •    Water use restrictions.

As  already noted,  these response procedures  constitute the  most relevant part of the
contingency plan during an actual supply disruption event.  In order to highlight these
procedures for easy reference during an event, therefore, planners might want to distinguish
them with the use of colored paper or indexed tabs, or bind the entire response procedures
section separately from the  rest of the plan.

      This section discusses the purposes for and potential uses of these various response
procedures in more detail.  Planners should recognize that although this list of procedures
is not exhaustive, it is fairly comprehensive and  may entail more effort than some localities
may require.  In developing a local plan, therefore, planners should consider both the
practicality and feasibility  of  these  recommended  options in  order to  identify  which
procedures are most appropriate.

Emergency Identification

      In the  initial stages of any emergency it is critical to gather as much information as
possible about the disruption incident as well as circumstances contributing to the situation.
Because quick response minimizes the potential effects of an incident, utilities should take
steps to encourage and facilitate the  prompt reporting of possible problems by their
employees, police and fire personnel, and the public. This can be accomplished through
education and through the use of simplified notification procedures.   Exhibit 2-9 provides
an  example of a consumer call-in notice.

      Appendix I presents a sample emergency  notification report which includes a section
for recording the specifics related to an emergency.  Communities that consider chemical
contamination of their aquifer to be a priority threat may want to prepare an additional
sheet, similar to that shown in Exhibit 2-10, for reporting of chemical incidents.

       Copies of the emergency response notification form could be provided to potential
dischargers to familiarize them with information needed at the time of an incident.  A copy
of the form should be located at  the front of the plan to enable ready access whenever an
incident is reported.

       Utility personnel should  use the U.S. Department  of Transportation's  (DOT)
Emergency Response Guidebook (available from DOT's Washington and Regional offices)
to  help identify hazardous materials.   Additional information about  the identity and
characteristics of chemicals is available by calling CHEMTREC (800-424-9300), a service
provided by the chemical industry.   Another  potential source of information about
potential supply disruption problems are the emergency notification reports provided by
spillers of hazardous chemicals under Section 304 of SARA Title III (discussed above).
These reports go to a community's LEPC.

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                                                                          Page 45
                                   Exhibit 2-9

                   EXAMPLE OF CONSUMER CALL-IN NOTICE
The following notice may be printed on the back of water bills to advise consumers on
how and where to report potential or actual water supply system emergencies.
                                     WATER SUPPLY SYSTEM
The following may constitute an emergency:

      1.    Vandalism of Water Supply Facilities
      2.    Loss of Water Pressure
      3.    Leaking Water
      4.    Sudden Changes in Water Quality
      5.    Spills of Chemicals or Petroleum Products
If you observe any of these conditions, please telephone the
system immediately.
     Business Office

     Water Treatment Plant

     After Normal Business Hours
water supply
If there is no answer at any  of the above numbers, please contact the Police/Sheriffs
Department at

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                                                                                     Page 46
                                     Exhibit 2-10

           EXAMPLE OF REPORTING FORM FOR CHEMICAL INCIDENTS
Identity of contaminant material:

      Manifest/shipping invoice/billing label

      Shipper/manufacturer identification

      Container type

      Placard/label information

      Railcar/truck 4-digit identification number

      Nearest railroad track intersection/line intersection
Characteristics of material, if readily detectable
(for example, odor, flammable, volatile, corrosive)
Present physical state of material (gas, liquid, solid)
Amount already released
Amount that may be released
Other hazardous materials in proximity
Whether significant amounts of the material appear to be
entering the atmosphere, nearby surface water, storm drains,
or soil
Direction, height, color, odor of any vapor clouds or plumes
Weather conditions (including wind direction and speed)
Local terrain conditions
Personnel at the scene

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                                                                              Page 47
      In short, initial information is critical.  Answers  to some of the key notification
questions may be unknown by the caller, but it is important to gather as much information
as quickly as possible to facilitate decisions on public notification.  Once the emergency has
been identified with some specificity, the individual who receives a notice must contact the
response team.  This process is facilitated through use of a formal notification roster (as
described in the following section).

Notification Roster

      Immediately following the incident report form, the contingency plan should contain
an emergency notification roster. The roster will list the  names and telephone numbers of
all of the personnel who might be involved  in responding to an incident.  Exhibit 2-11
provides an example  of such an emergency notification roster, illustrating the wide range
of parties that  should be made aware of a disruption incident.

      In addition to the notification roster, the specific procedures for notifying responders
must be presented in the plan.  Some communities may prefer to identify one or two
individuals responsible for contacting all key personnel. This  approach has the advantages
of simplicity.  Another system is the
"cascade" or "pyramid" system, in which each  person calls two people on the next level of
the pyramid. If someone cannot be reached, the caller is  responsible for notifying the next
two people  in the pyramid.  No matter what notification  procedure is adopted, it must be
described clearly in the plan.  One procedure for normal work hours and an alternate for
off-hours may be necessary.

Overview of Incident Direction and Control

      Because speed of response is by definition essential in water supply emergencies, the
response chain-of-command must be determined prior  to an emergency, thus averting
confusion which could aggravate the emergency and prevent a coordinated response effort.

      The  designated response coordinator should  work with  the  planning  team to
determine:

      •     What will be the chain-of-command?

      •     Who has overall responsibility for incident command?

      •     Who is in charge of important support functions?

      •     Who will have advisory roles (and what will their precise roles be)?

      •     Who will make the technical recommendations on response actions
            to the lead agency?

      •     Who (if anyone) will have veto power over response decisions?

      •     Who is responsible for requesting  assistance from  outside the
            community?

      •     Who will make decisions  on water-use restrictions?

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                                                                                     Page 48
                                        Exhibit 2-11

                    EXAMPLES OF EMERGENCY NOTIFICATION ROSTER
Emergency Plan for Water Supply Should Include Names and Phone Numbers for:

•     Key Water Supply System Personnel (office and home,
      with hours)                                                   	
      Key Community Leaders (office and home, with hours)
      Local Public Health Engineer (office and home, with hours)
•     Fire Department
•     Police, Schools
      Hospital and Ambulance Service
      Nursing Homes
      Dialysis Users
      Neighboring Water Supply System Managers
      Power Company Emergency
      Highway Department
      All Key Suppliers/Vendors/Technical Representatives of
      Water Supply Related Equipment, Chemicals, and Supplies
      Key Personnel of Major Industrial/Commercial Water Users
      State and Local Emergency Agency
      State and Local Civil Defense Offices

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                                                                              Page 49
Internal Communications

      When responding  to a  supply disruption  incident,  especially  in an  emergency
situation, it is  essential that all those  involved are kept informed as the situation unfolds.
Persons with authority need to be kept up-to-date on response actions and results in order
to make appropriate decisions.  Reliable channels of communication should be established
at the planning stage so  that information and instructions  reach .people quickly  and
accurately  in  an emergency.   In addition, the format  to be  used for recording  and
transmitting essential  information should be defined (for example, telephone or two-way
radio frequencies).

      Certain types of emergencies, such as fires or floods, may disrupt normal power or
communication lines.  Local police, fire, or civil defense personnel (who may be members
of the planning team) can  indicate what arrangements have been made for power and
communications systems  in the community in the event of such  emergencies.  If these
systems are not adequate to meet the water system's needs, other arrangements for back-
up power and  communications, such as independent generators and two-way radios, must
be made.
Public Communications/Community Relations

      Effective communication with the public both  before  and after a water supply
disruption incident is important  for a number- of reasons.  Health considerations  may
require prompt public notification, as in incidents where boil-water notices are necessary.
Public notification may also be a legal requirement for many situations under both the Safe
Drinking Water Act and State statutes.  In addition, effective communication can minimize
public confusion and frustration and can help to  secure the public's cooperation  in
implementing  such response measures as water conservation.

      To be  effective,  public communication  must  be prompt, frequent,  accurate,  and
credible.  Moreover, the credibility of water supply system personnel must be established
at the outset of any problem.  Appendix J identifies public communication procedures that
should be taken before and after a disruption, along with ways the planning process can
lay the groundwork for implementing  these communication steps. Appendix J also provides
sample notices for media release and direct public communications, which can be used  to
ensure the credibility of emergency responders by facilitating the provision of accurate and
timely information  to  the  public.   A final and  principal  component  of  a public
communication program should be the education of consumers before a problem arises  so
that they can be on the look-out for  potential problems and will understand the basis for
any water use restrictions.

      Form  is often as important as content  when communicating potentially volatile
material to the public.  The following are suggestions  concerning the manner of presenting
information about a water disruption event:

      •    Notify the public as quickly as possible following the discovery of
           a problem.  It  is crucial to credibility that initial notification be
           through water supply personnel - not State or Federal personnel
           or press leaks.

      «    Choose a spokesperson  likely  to  communicate clearly with the
           public and to  inspire confidence.  The public generally  has  a
           preexisting reservoir of trust in the public water supply system and
           the person selected to speak on its behalf should be careful not to

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                                                                              Page 50
           deplete it.  Keep local politics in mind and select a respected,
           neutral individual.

      •    Public anger and frustration are more likely to arise than panic.
           Avoid defensive postures and speculative responses in the face of
           negative  reactions.   It is better  to admit  ignorance  than  to
           speculate.

      •    Do not raise false hopes concerning the remedial time-frame or
           attempt to trivalize problems involved in responding to a serious
           water supply disruption.

      •    If  the  incident  is  substantial,  failure to  convey  adequate
           information  to  the public  could  be  particularly  polarizing.
           Including the involvement of a person from the "public," therefore,
           would provide a gesture of openness and respect.  Such a person
           need not necessarily be involved in the decisions, but should  be
           allowed to observe them impartially and in their entirety.

Ongoing Incident Assessment

      After response procedures have been initiated, the water supplier must take steps
periodically to evaluate the situation and determine the short-term and long-term impacts
on water supply.  The major questions to be answered in most cases will include:

      •    What is the current status of the water supply system?

      •    What is the current status of the response effort?

      •    How long and what will it take to return the system to normal
           operations?

      •    Should any of the response activities be changed or should new
           activities  be initiated?

      The  answer to these  questions may change  as  the response effort  progresses.
Therefore,  it is important to ask these questions on a  periodic basis.  As the answers
change, the response team may wish to develop alternative response strategies:

      •    Is there a need to implement water  restrictions?  To advance to
           the next stage of restrictions?

      •    Does the situation require customers to boil water before drinking?
           Can an existing boil water requirement be lifted?

      •    Should steps be taken  to obtain water from alternative sources?
           How much?   From where?
Contamination Assessment

      If the supply disruption is the result of a contamination event, responders may want
to undertake a  contamination  assessment.  Contamination may occur  through naturally
occurring  constituents  leaching  into  the  water  supply,  through the migration  of
contaminants introduced into the aquifer from agricultural or waste disposal practices, or
from the accidental  release of contaminants (e.g., truck spill or poor materials handling

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	•   	.	Page 51


practices).  Whatever the source of contamination,  a water supplier must maintain an
ongoing sampling and monitoring program  to ensure that its treatment system is capable
of handling the types and levels of contamination present in its water sources.  Certain
steps in response to evidence of contamination must also be taken:

      •     Notify the public.

      •     Identify and isolate the source of contamination,  if known. If not
            known, identify and isolate contaminated water supplies.

      •     Map the  extent of contamination.

      •     Determine appropriate responses.

      The appropriate responses for each contamination event will be dependent on the
nature of the specific occurrence.  The first priority for most spill scenarios, for instance,
will  be containment  of  the material followed by removal of the contaminant and any
contaminated soils, and/or  pumping and treatment of contaminated waters.   For water
supplies that are 'threatened by plumes of contamination  already in  the aquifer, the
alternatives  may include:

      •     Connection to alternative supplies;

      •     Development of new wells;

      •     Remediation of the  aquifer;

      •     Treatment at the well or point-of-use; and

      •     Blending  of water supplies to achieve acceptable  levels.

      The response to any contamination incident should involve an ongoing program of
monitoring and sampling to follow  the extent of contamination.   The contingency plan
should identify  the necessary procedures for  establishing an adequate monitoring program,
including such considerations as:

      •     Identification of the contaminated area;

      •    Installation of monitoring wells;

      •    In-house laboratory capabilities; and

      •    Location and turn-around time for water  analyses by contractors.

Special Procedures for Non-Contamination Events

      Water supply disruptions will often be caused by natural phenomena, such as storms,
lightning, floods,  or  earthquakes,  which  can   result in power  outages  or physical
consequences to the supply and distribution systems  (for example, well  collapse or line
breakage).  The contingency planners in their prioritization process (discussed in Section
2.3) should identify the most likely candidates for such occurrences and include response
scenarios for the most likely events.

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                                                                              Page 52
Obtaining Alternative/Supplementary Water Supplies

      In developing the background information described in Section 2.3, water supply
contingency planners will have identified potential sources of alternate water supplies.  The
response procedures section should contain a listing of the sources of alternate supplies to
be used for various contingencies and should identify specifically the procedures necessary
to access those supplies.  Planners may wish to list the sources according to quantity
available, ease of access, cost associated with supply, or some other hierarchy.   Exhibit
2-12 represents an  example of a call-up list for alternate water supplies.

Water-Use Restrictions

      If the water lost due to a supply disruption cannot be readily replaced, the response
team may choose to impose water use restrictions.  Planners should consider whether to
employ  categories  of water-use  restrictions  based on the  severity of the  disruption.
Appendix K contains one example of water-use restrictions based upon classifications of
use.  If such restrictions are adopted, planners should establish a hierarchy of uses, as well
as objective "trigger points" or thresholds for imposing increasingly stringent restrictions on
those uses, that best reflect their community's  needs.  For example, the system might call
for voluntary cutbacks when supplies fall below 80 percent of system capacity, mandatory
cutbacks at 70 percent, and  bans on  certain  uses  at 60  percent.  The program of
restrictions, as well as the procedures  (typically through notification of water users in the
mail and through the media) for implementing those restrictions, should  be documented
in the plan.

2.5   ADDRESSING PROBLEMS -- FUTURE STEPS TO BE TAKEN

      The core of  a water supply disruption contingency plan is the response procedures
section, followed in importance  by the background description of system conditions and
potential disruption threats. A plan which stops there, however, is not being utilized fully.

      The process  of developing a contingency plan typically helps a community identify a
variety of tangible actions that should be taken to either reduce the vulnerability of the
 system to  disruptions  or improve the  community's  response capabilities.   These  steps
 generally fall into  four broad categories:

       •     Preventing or mitigating emergencies;

       •     Training local responders;

       •     Educating the public; and

       •     Reviewing and updating the plan.

 Preventing or Mitigating Emergencies

       While certain water supply disruption emergencies are unforeseeable, the planning
 process often identifies problems or potential contingencies that, if addressed promptly, can
 be  prevented or mitigated.  Examples might  include unregulated land uses that threaten
 chemical contamination of an aquifer, shortages of critical response equipment, or the lack
 of a mutual aid response agreement with a neighboring community.  The development of
 background  information  (see Section 2.3  above)  is typically where these situations will
 come  to  light.   The plan itself can also incorporate such prevention and mitigation
 measures. This incorporation will be easier if the plan contains a specific agenda of what

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                                                                                   Page 54
     measures are necessary, who is responsible for them, and when they will be done.  As new
     measures are adopted, they should be incorporated into the contingency plan.

     Training Local Responders

           In order for a plan to be implemented effectively in actual disruption incidents, local
     response personnel may need training in their specific tasks.  Making sure this  training
     occurs is easier if the plan specifies what the responders need to know and how and when
     they  will be  trained by  providing, in effect, a training  agenda and a set of  training
     procedures.

           Training can be accomplished  in several ways.  One way is to educate responders
     using training courses in which each person's role and responsibilities are clearly identified
     and explained.  Another method is  to provide on-the-job training through the  types of
     emergency simulation exercises described in Chapter 5. Such exercises include full-scale
     field  exercises, functional exercises, and tabletop exercises.  There are a number of  agencies
     and organizations that provide training assistance including:

            •     State agencies and training institutes;

            •     Federal emergency and hazardous materials training;5

            •     Universities or community colleges;

            •     Industry associations; and

            •     Private consultants.

      Communities should be aware that training is an ongoing need. New responders will need
      to be trained and veteran responders will need refresher courses  at periodic intervals.

      Educating the Public

            Public  knowledge and confidence in  system  management  can be essential in
      undertaking a successful response.  A severe water disruption crisis,  for  example,  may
      require that stringent water conservation measure be implemented.  By educating the public
      ahead of time about their role in conservation (for example, by using brochures, water-bill
      mailouts, public forums, or press articles based on plan information  relevant to the public),
      their understanding and cooperation will greatly improve during an emergency. Again,
      building and maintaining public confidence is an ongoing process.

      Reviewing and Updating the Plan

            Keeping a contingency plan up-to-date is essential to its continued usefulness.  The
      easiest  way to ensure that  a  plan is kept current is  to build the procedures for review and
      update directly into the plan itself.   Chapter 5 discuses these procedures in some depth.
      The point here is that these procedures should be included as an integral  component of
      the  plan.
    5 Including the U.S. Environmental Protection Agency, Federal Emergency Management Agency,
Occupational Safety and Health Administration, Department of Transportation, and United States Coast
Guard.

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                                                                              Page 55
                       UPDATING AND REVISING THE PLAN

            Jackson, Tennessee, has completed  its emergency response plan and
      currently  Is  in  the process of updating  names, Addresses^ and telephone
      numbers.  Jackson's plan is designed to provide detailed resource information
      to- those who respond to water supply emergencies,  For ease of ase> the plan
      uses different paper colors for each section and distinguishes between internal
      an,d external resources.

      Lessens learned:  The use of visual aids saeh as different paper colors in a
      contingency planning document can enhance the flocament's
2.6   BUILDING CONSENSUS FOR THE PLAN

      Once a draft plan is complete, but before the plan is officially approved or adopted,
it should be reviewed carefully. The success of a plan may be dependent on its acceptance
by the local community.  Involving as many interested parties as possible at the review
stage of the plan will improve the quality of the plan and build community support for the
plan.

      The review process begins with review of the draft plan by the planning team itself.
This  review  consists  of evaluating the  plan  for  adequacy,  clarity,  coherence,  and
completeness.  Even though team members may have worked only on specific parts of the
plan, it is still helpful for the team as a whole to review the entire document to make sure
that no gaps or  inconsistencies exist.

      Once the internal review process is complete, an external review can help legitimize
the plan's authority and build community support for it. Several distinct types of external
review might be considered, including:

      •    Expert  review:   Typical candidates  for expert  review include:
           industry officials, college professors, and other officials from nearby
           jurisdictions.  It is  important that  the individuals selected for the
           expert review be able to provide objective reviews of the plan.

      •    Local official review:  Here an individual or group with oversight
           authority reviews the plan.  This stage of review should come after
           the comments of the expert reviewers  have been addressed  and
           appropriately incorporated.

      •    Community input:  Local community interests should be invited to
           participate in  the review.  There are several ways to involve the
           local community, including community workshops, public notice of
           comment periods,  public  meetings,  invited reviews of special
           interest groups, and advisory councils.

      •    State/Federal review:  Communities may request that appropriate
           State or  Federal  officials  review a  plan.   There  may  be  a
           requirement in the State WHP program that the plan must comply
           with in order to be approved or before funding can be provided.

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                                                                               Page 56
           State agencies  can also help  coordinate the plan  with other
           contingency plans.
      This chapter has described the development of a local  contingency plan.  While
several specific planning activities have been described, it is important that the general
themes of this process be reflected throughout the plan:  keep the plan simple in structure
and clear in language; tailor the plan and the response procedures to local circumstances
and needs; make  the plan as  "user-friendly" as possible; and  make  use  of all available
expertise in the planning process itself.  Keeping these themes in mind should help make
the planning process less imposing and the resulting plans more effective.

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                                                                              Page 57
                                   SECTION H
         CONTINGENCY PLANNING AT THE STATE LEVEL
      The first section  of this TAD focused on contingency planning at the local level.
This  emphasis reflects  the primary role that  local governments typically  play  in  both
providing public water supplies and responding to supply disruptions.  The focus in this
second section shifts to the State level.  The Safe Drinking Water Act Amendments of 1986
(SDWA) established six key elements, of which contingency planning is one, that States are
required to incorporate in their  State Wellhead Protection Programs (WHPP).  The
contingency planning element specifies that each State program shall include contingency
plans for the location and provision of alternative drinking water supplies for each public
water system in the event of well or wellfield contamination (see Appendix A, page A-2).
The reason States have been delegated such an extensive role in contingency planning is
that State government is the most appropriate level of authority to organize the planning
process and  to  encourage  consistent  and comprehensive contingency  planning and
implementation at the local level.  Many States also play a critical back-up role to  local
responders, making  available equipment and  expertise when  water supply disruptions
overwhelm local capabilities or require  specialized response expertise.

      Although the SDWA requires States to develop Wellhead Protection Programs that
provide for the development of local contingency plans, States are not required to prepare
separate State contingency plans per se.  In fact, most States will likely delegate much of
these planning responsibilities to local governments because of the site-specific nature of
contingency planning.  Nonetheless, a  formal State contingency planning effort, if not a
separate State plan, can help the State discharge its responsibilities by establishing standards
for local planning, providing guidance to assist local planners, and identifying resources
more appropriately provided at the State level.  This section on the State planning process,
therefore, is designed to help States undertake formal contingency planning efforts.

      Exhibit 3-1 provides both a flow chart of the planning process at the State level and
a "road map" of Section II.  Parallelling Section I, the discussion here is divided into two
chapters.   Chapter 3 focuses  on organizing the  State  planning  process and Chapter 4
provides concrete suggestions on developing a State plan itself.

      The  discussions of key themes  and  plan development  in  Section I  — although
explicitly geared to local planners - are important for State planners as well.  Recognizing
this fact, the discussion in Section II is generally shorter than in Section  I, with the reader
referred back  to corresponding discussions  in  Section  I as appropriate. Beyond these
specific references, however, State planners will want to  read Section I to glean as much
guidance as possible that may be relevant to their own  State planning effort.  Moreover,
the local planning guidance provided in this TAD may  be useful as a  model for States
developing their own local  planning guidance,  either as part of the State plan or  as a
separate document.

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                                                                          Page 58
                                   Exhibit 3-1
                 CONTINGENCY PLANNING AT THE STATE LEVEL
                                                        Identifying Available
                                                          State Planning
                                                           Resources
                                                          (Section 3.3)
            Identifying the
            Lead Agency
            (Section 3.2)
                            ORGANIZING THE STATE
                              PLANNING PROCESS
                                   (Chapter 3)
                                                                       Assigning and
                                                                     Managing Planning
                                                                       Responsibilties
                                                                       (Section 3.4}
AsMcatog SUUvrtto
 Ptem*B Nwda and
 tht Rote of tt» State
  (Section 3.1)
/-"     ^x
   Focusing on
   Key Themes
   (Section 4.1)

^	^ '"
                                                                    Building Consensus
                                                                      for the Plan
                                                                      (Section 4.6)
                              DEVELOPING THE
                                 STATE PLAN
                                  (Chapter 4)
                                                                          Addressing
                                                                           Problems
                                                                          (Section 4.5)
Placing the Plan
  hi Context
 (Section 4.2)
                                                     Water Supply
                                                   Disruption Response
                                                   Procedures and Local
                                                    Planning Guidance
                                                     (Section 4.4
                    Background
                    Information
                   (Section 4.3)
                                  REVIEWING AND
                               UPDATING THE PLAN
                                     (Chapter 5)

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                                                                             Page 59
 CHAPTER 3:  ORGANIZING THE STATE PLANNING PROCESS
      Organizing the  water supply contingency planning process is as important to the
ultimate effectiveness of a plan at the State level as it is in the development of local plans.
This chapter provides specific suggestions on organizing the planning process at the State
level, including assessing statewide planning needs and the appropriate role of the State,
forming the  planning team, choosing  the  lead agency, identifying  available planning
resources, and assigning and managing planning responsibilities.

3.1   ASSESSING STATEWIDE PLANNING NEEDS AND THE ROLE OF  THE STATE

      The role of the State is primarily to respond to the wellhead protection  requirements
established by the SDWA.  In doing so, a State needs to concentrate its contingency plan
on its own particular needs if that plan is to be effective.  Focusing planning efforts in this
way  increases the usefulness of the State plan in emergency response situations; it also
increases the efficiency of the planning process, making the most productive use of limited
planning resources and the limited time of busy planning team members.  The State role
also  will influence the contents of the State plan and  the level of detail  in particular
sections of the  plan.

      The role  of local  authorities,, the  fromvline in  responding  to  supply disruption
incidents,  is relatively straight-forward.  There is greater diversity, however, in the roles
assumed by States.  State roles generally divide into two broad categories:

      •    Delegating contingency planning responsibility to local governments
           within a  framework established by the State; and

      •    Providing back-up support for local responders in supply disruption
           incidents.

      Probably  the most effective way for the State to fulfill these roles will be to establish
a formal State  contingency plan.  In  developing this  important  plan, the State planning
team needs to keep the "big picture" in mind, linking its information gathering efforts to
the purposes and objectives of the plan.  Activities particularly useful in this process might
include:

      •    Undertaking "broad-brush," statewide assessments of local water system
           characteristics, ground-water  supply vulnerability,  and water  supply
           replacement options;

      •    Evaluating available State technical, logistical, and financial resources
           available to support local planning and response capabilities;

      •    Focusing  team decision-making  on developing appropriate State
           response  procedures, including  criteria  for  determining  the
           appropriate level of  State  response  to  different  types of local
           supply disruptions;

      •    Deciding on the most appropriate framework for local planning  efforts,
           if the State plan is intended to serve a guidance function; and

      •    Linking the WHP contingency planning process with other State planning
           efforts, such as SARA Title III plans,  civil defense plans, and so on.

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                                                                             Page 60
3.2   IDENTIFYING THE LEAD AGENCST AND FORMING THE STATE PLANNING
      TEAM

      The  State  planning process will most  likely begin with  the passage of  State
legislation, or perhaps as a Governor's executive order, implementing the State's Wellhead
Protection Program (WHPP) as required by the Safe Drinking Water Act Amendments of
1986.  The State WHPP should in turn assign  responsibility for contingency planning to
one or more agencies or individuals.  The States should establish  the lead agency for its
contingency planning efforts so that the  designation is consistent with Wellhead Protection
Program roles  and  responsibilities as  required by  the 1986 SDWA amendments  (see
Appendix A).

      Once the lead agency is identified, the next step is the formation of a contingency
planning team including representatives of all agencies (as well as select private interests)
that have a role to play in responding to water supply disruptions or have expertise to lend
to the preparation of the plan.  Exhibit 3-2 provides an illustrative list of the types of
agencies and private sector interests that  might be represented on a State contingency
planning team.   Section  1.1, which offered advice on  forming a local planning team,
provides many suggestions that are equally relevant to the State planning process. Readers
may wish to refer back to Section 1.1 for more information.

3.3   roENTIFYING AVAILABLE STATE PLANNING RESOURCES

      Tight budgets are as much a reality for most State governments as they are for local
jurisdictions.  The emphasis placed in  Chapter 1 on making the most productive use of
existing  planning resources  ~ including both available expertise and  planning-related
documents - applies equally to State contingency planning teams.  Resources necessary for
a State effort, thus, might be sought from  a number of  sources:

      •     State agency staffs  are a  particularly  good place for  planning team
            members to look for both expert advice and  for assistance in writing and
            reviewing key parts of the  plan.  States typically have a larger pool Of
            personnel than  local governments to access for technical and planning
            expertise.

       •     Members of the State Emergency  Response Commission (SERC), the
            body created under the Federal SARA Title III to  coordinate the local
            Title III planning efforts of Local Emergency Planning  Committees, may
            be especially valuable contributors  to the planning  effort.

       •     State planners may also' turn to water system  managers and local planners
            from the larger, more sophisticated communities in their State.  Because
            they are likely to feel they have a large stake in the viability of the State
            plan, such local personnel  may be willing to invest time in developing
            that  plan.

       •     Local government representatives, technical  experts, and others bringing
            specialized perspectives to the  State  planning effort  may either be
            included on the planning team itself or enlisted in an "advisory board"
            or other adjunct body.

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                                                                      Page 61
                               EXHIBIT 3-2

POTENTIAL MEMBERS OF A STATE WHP  CONTINGENCY PLANNING TEAM
   Water supply department
    State Engineer
   Water quality department
    Local government representatives
   Emergency management agency
  .Health department
   Environmental   protection
   department
   Governor's Office representative


   Attorney   General's   office
   representative
   State  police   or   public  safely
   department
   State Civil Defense Agency
    Statewide   industry   association
    representatives
                                        •    Statewide    citizen   group
                                             representatives
                                        •    Technical  experts   (hydrologists,
                                             engineers)
     Water quality laboratories
                                             Equipment and response contractors
•    Federal   agency   representatives
     (FEMA, DOD, USDA, DOT, EPA)

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                                                                             Page 62
      •    Local plans, at least for the largest communities in the State, may also
           be worth examining. Well-crafted, pre-existing local plans can help State
           planners get a sense for how water supply disruption  response actions
           are actually managed at the local level.  Local plans will also give State
           team members a feel for local hydrologic conditions, disruption threats,
           and response  capabilities.

      State contingency planners, however, must be careful to evaluate the adequacy and
relevance of existing planning documents.  While much useful  information, response
procedures, and other materials may be gleaned from existing plans, it is important not to
simply borrow material without asking questions about how appropriate the materials are
in a water supply contingency planning context and about how useful existing procedures
have been in guiding previous response actions.

3.4   ASSIGNING AND MANAGING PLANNING RESPONSIBILITIES

      Once  the planning process  begins, the most important job of the  leader of the
planning team is to  keep that process on track towards  completion  of an effective plan.
This requires  close monitoring of team members' work and facilitating consensus among
team  members on key procedures and local planning guidance.   This task can be even
more challenging at the  State level than  at the local level simply  because a statewide
planning team is more likely to include people  who  do not know each other or have
experience working  with each other  (local planners and  water system managers, for
example).

      The first management task is to make appropriate assignments of specific tasks to
planning team members.  These tasks  (discussed below in Chapter 4) include:

      •    Assessing the characteristics  of water systems statewide;

      •    Assessing the vulnerability  of ground-water supplies statewide,
           including a review of State emergency response  plans developed
           under Section 1413 of the SDWA;

      •    Assessing water supply replacement options statewide;

      •    Evaluating the State's technical, logistical, and financial resources
           to support local response activities;

      •    Developing effective  action-level systems  to  determine when the
           State's support resources should be provided;

      •    Developing   guidance and  standards to  direct   local  'plan
            development;

      •     Identifying future steps that should be taken to prevent/mitigate
            future disruptions  and improve the State's ability to  respond to
            major supply disruptions; and

      •     Organizing a process for reviewing and updating the plan.

By their  nature, many  of these tasks will require involvement  by more than one team
member.  When assigning planning  responsibilities,  the planning team or team leader
should be sure  to clarify the process by which one agency will take charge when two or
more agencies have  similar or concurrent plan development and/or implementation roles.

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                                                                              Page 63
            CHAPTER 4:  DEVELOPING THE STATE PLAN
      Developing a State contingency plan involves a complex set of tasks that need to be
coordinated with other wellhead protection efforts and focused in order to ensure that the
resulting plan is useful under response conditions.  It is also important to develop the plan
in an efficient manner.

      The purpose of this chapter is to facilitate the development of State plans, which in
turn will guide local  public water supply system managers in developing their plans, by
providing specific suggestions that State  planners can follow.  The chapter begins with a
discussion of key general planning themes in Section 4.1, which is then  followed by several
sections organized according to how a State plan might be structured:

      •     Section 4.2 describes a  typical plan introduction;

      •     Section 4.3 reviews  the types  of background information and
            analysis associated with plan development;

      •     Section 4.4 describes how response procedures might be developed
            and used; and

      •     Section 4.5  describes how a plan might incorporate  identification
            of specific  future steps that a State might  take to help local
            communities  prevent  or mitigate  the   impacts  from  supply
            disruption.

Finally, Section 4.6 describes the process for building consensus in support of the plan.

      Exhibit  4-1  provides an  example table  of contents  for  a State water supply
contingency plan. Although State plans will vary in structure and detail  more so than local
plans, because of the wide variety of State governmental structures, priorities, and available
resources, this exhibit offers a starting point for State plan development.  The remainder
of this chapter  discusses  in more  detail how a  State planning team  might  go about
developing a water supply contingency plan based in  general on  the outline presented  in
Exhibit 4-1.
4.1   FOCUSING ON KEY THEMES

      Planning team members developing a State contingency plan should keep a number
of key themes in mind.  The  key themes presented in Section I, such as keeping the plan
simple and making sure  it is clearly written and "user-friendly," are as applicable to the
State planning process as they are at the local level.  In addition to these themes, State
planners should bear in mind several themes unique to the State planning process:

      •     Because contingency  planning  is  only  one element in the Wellhead
           Protection Program requirements set out in the SDWA, State planners
           first need to ensure that the State water supply contingency plan is fully
           integrated with the State's Wellhead Protection Program.  Consistency
           with the  more comprehensive WHPP, which governs  local wellhead
           protection efforts, will also help local communities understand how their
           plans will mesh with the State plan.

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                                                                         Page 64
                                  Exhibit 4-1

                     ILLUSTRATIVE TABLE OF CONTENTS
                   FOR A STATE WHP CONTINGENCY PLAN
I.    Introduction

     Directory of Information
     Overview of State Wellhead Protection Program
     Summary of Statewide Planning Needs
     Objectives of the Plan
     How the Plan was Developed
     Relationship of the Plan to Other Contingency Plans

n.   Background

     Statewide Water System Assessment
     Statewide Ground-Water Supply Vulnerability Assessment
     Statewide Water Supply Replacement Assessment
     State Support Resources

HI.  Water  Supply Disruption Response Procedures

     State Response Procedures
     Guidance for Local Response

IV.  Future Steps to be Taken

     Action Steps to Prevent/Mitigate Emergency Impacts
     Training Local Responders
     Reviewing and Updating the Plan

Appendices

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                                                                              Page 65
      •     State planners should strive to make the plan as accessible and useful to
           local communities as possible.  It is vital that local communities have a
           clear understanding of how to access State resources during an emergency
           and know exactly what backup support they can expect from  the State.

      •     State planners  should focus the plan on those disruption threats
           that are most likely to require State response actions.  These are
           likely to be disruptions large enough to affect more than  one
           community or events posing threats requiring specialized expertise
           that may not be available  at the local  level (analytic laboratory
           services for contamination events, for  example).

      •     State planners  should take a more "broad-brush" perspective  than their
           local counterparts,  basing their  response procedures  and  planning
           guidance on a larger-scale, less detailed assessment of statewide ground-
           water supply conditions and supply disruption capabilities.

      •     State planners should think of the State WHP contingency plan as
           a  dynamic  document that must be  kept up-to-date to reflect
           changing conditions  and  statewide response needs.   Changes in
           local conditions and response capabilities may affect the specific
           assistance the State,  in its role as  a back-up to local responders,
           may be called upon to provide.

      By starting out with  these key themes  in mind, planners should be able to develop
State plans that meet both  the needs of the State in terms of comprehensive ground-water
protection and the needs of localities in terms of safeguarding community water supplies.

4.2   PLACING THE PLAN IN CONTEXT WITH AN "INTRODUCTION"

      State plans should begin with an introduction designed to serve two  purposes.  First,
the introduction should place  the plan in context by providing a brief  overview of the
plan's origins and objectives and by explaining how the plan relates to other State planning
efforts.   The  form and objectives of the  plan must  be based on  the State's  Wellhead
Protection Program goals  and activities.   Second, the introduction  should  indicate how
State responders should use the procedures in the plan, as well as how, for the  benefit of
local officials, local  plans should be  integrated with the State plan.  Direction for local
planners is of utmost importance because these planners will be making the "front-line"
decisions  on how to best protect community water supplies and may need to access State
response assistance quickly.

      The content of a State plan's introductory  section can follow essentially the same
format as that presented for local plans in Section 2.2 of this TAD.  State planners should
review Section 2.2 as a starting point for developing an introduction to their plan, keeping
in mind  the  State's objectives  as indicated  in  its Wellhead Protection Program and
necessary differences in perspective between the State and local  levels.

4.3   BACKGROUND INFORMATION

      State water planners should begin their efforts  by evaluating the current status of
water supplies in the State and existing capabilities  for responding to  threats to those
supplies.  For planning purposes, this section of the document should  rely on existing
information.   Few, if any, States  can afford to  develop detailed analyses for every ground-
water system within the State.  These assessments, therefore, should not be overly detailed
and  should be based on information that can be found in existing water data bases, reports

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                                                                              Page 66
generated by previous water supply emergencies, and other State and local contingency
plans.   Most States should have  on file an emergency plan for water supply that was
prepared in support of their  State primacy  program  under Section  1413  of the Safe
Drinking Water Act. Four key components of this background evaluation include:

      •    Statewide water system assessment;

      •    Statewide ground-water supply vulnerability assessment;

      •    Statewide water supply replacement assessment; and

      •    Review of State support resources.

      In undertaking statewide water system and vulnerability assessments, State planners
should consider the level of resources available for planning purposes.  It may be  more
efficient for  the State to  collect and  aggregate  local water  system and  vulnerability
assessment data gathered  during  local planning efforts, as opposed to collecting such
information separately and duplicating local efforts.  Under this  approach, the State could
focus its  efforts on responding  to general  local needs  as defined by the localities
themselves, rather than directing the development of local plans. Activities that  a  State
might undertake in order to perform statewide water system, vulnerability, and replacement
assessments, and to  develop a  support strategy for localities based on those assessments,
are presented in more detail below.

Statewide Water System Assessment

      In order to develop an effective statewide contingency strategy, State planners must
determine both the  physical status of local water supply systems and the available local
response capabilities.  The first task will involve answering some basic questions relating
to ground-water supplies in the State, including:

      •    How many systems in the State are dependent on ground water?

      •    Where are they located?

      •    How large a population do these  systems serve?

      •    Do any  of these systems have excess capacity?

      •    Are any of these systems at full capacity?

      •    Are any of these systems interdependent either through use of the
           same  aquifer or  through interconnections  of their distribution
           systems?

      •    What  systems have locally available sources of alternative supply?

The contingency plan should incorporate the  results of this analysis through such means
as charts or tables that enumerate the various systems along with data indicating capacity,
number of wells, population served, or other information.  Planners  may want to establish
categories  of systems within  the State, grouping systems by  criteria such  as common
aquifer, population served, or  relative dependence on ground water.

      Once they have  identified those systems most dependent on ground water,  State
planners should undertake an evaluation of these systems  to determine whether they

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                                                                               Page 67
possess the necessary administrative, technical, and financial resources to respond to a
water supply emergency.

      •     Some communities will already have adopted a local contingency plan.
            These  plans  can be  a wealth  of information  for State contingency
            planners.

      •     Other communities will possess  the abilities and resources, but require
            guidance from the State to develop a useful plan of their own.

      •     A third category of communities will require extensive assistance from
            the State in the event of any problem with their water supply system.

Planners may wish to create a hierarchy of systems, based upon local response capabilities.
This evaluation will help the planners to quickly determine what type and level of support
the State will need to provide should an emergency arise.   If resources  are limited, the
State may decide to focus planning efforts on areas that have the least capacity to respond
to emergencies, areas of heavy population, or those areas where problems are most likely
to occur.
Statewide Ground-Water Supply Vulnerability Assessment

      Under the SDWA, State Wellhead Protection Programs must identify anthropogenic
sources of contaminants within each wellhead protection area.  The information collected
in conjunction with a State's source identification efforts can therefore form the basis of
the vulnerability assessment in the State contingency plan. State emergency response plans
developed under Section  1413 of the SDWA may also prove useful.  If available, data
generated by previous water supply emergencies and existing data bases of land use and
water  resources can  be incorporated in the assessment.  Finally, the monitoring  and
vulnerability  assessments  required  of  public  water  suppliers   in  order  to  address
contamination by  volatile organic  compounds  (VOCs),  as  codified in the  Federal
Regulations  at 40 CFR   141.24(g),  might provide  useful  information  concerning the
frequency and location of VOC  contaminant sources.   This  wide variety of potential
information sources should allow planners to conduct a fairly comprehensive evaluation of
threats.  Exhibit 4-2 lists  some of these information sources.  Much of this information
may already be collected in one place.

      Once the existing contamination threats have been reviewed, the potential for future
problems in wellhead areas should be examined.  This step requires planners to develop a
map of wellhead areas supplying public water systems within the State (see Appendix A,
page A-3; Section (e)). This map and other supporting data should be used to:

      •     Identify wellhead areas where problems have occurred;

      •     Identify activities taking place in or near wellhead  areas with the
            potential to disrupt water systems; and

      •     Estimate the   number  of people served by  these water  supply
            systems.

      All of the categories of emergencies identified in Chapter 2 may be relevant to a
State contingency plan.   State planners, however, are specifically required to consider
chemical contamination under provisions of the Safe Drinking Water Act and SARA Title
III.  Exhibit 4-3 illustrates the types of factors that should go into a statewide evaluation

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                                                                     Page 68
                              Exhibit 4-2

       SOURCES OF INFORMATION ON POTENTIAL THREATS
                        TO GROUND WATER
State emergency response plans developed under Section 1413 of the SDWA

Source identification efforts required under the SDWA Wellhead Protection Program

Local public works departments                               .

City, regional, or State departments of environmental protection.

Environmental quality .engineering department     •

State and local health departments

State and local water, public water supply, or drinking water departments

State ground-water,office

U.S. EPA Office of Drinking Water

U.S. EPA Office of Ground-Water Protection                  .        ;.

U.S. or State Geological Survey                  :         .

Material Safety Data Sheets (MSDSs)  developed under Title III, of the Superfund
Amendments and Reauthorization Act (SARA) or  the Occupational Safety and
Health Administration^ Hazard. Communications Standard •  ;            ;

RCRA contingency plans prepared by owners  and operators  of hazardous waste
treatment, storage, and disposal facilities •

University personnel with expertise  in hydrology,  pollution control,  planning, or
related fields

Site visits or questionnaires addressed to water suppliers

Old aerial photographs (may be used to help identify abandoned waste sites)

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                                                                               Page 69
                                     Exhibit 4-3

                  EVALUATION OF CONTAMINATION THREATS
      State water planners should consider the following factors when evaluating potential
contamination of water supplies:

1)    Contamination incidents that may occur, including:

      a)    Acute  events  -  emergencies  and  accidents  resulting  in  ground-water
           contamination, and

      b)    Chronic events - the leaching of contaminants into ground water from a variety
           of sources over time.

2)    Possible sources of contaminants, including:

      a)    Industrial  sources  related  to  transportation,  use, production, storage, and
           disposal of hazardous and toxic materials, including:
                 railroads, highways, pipelines;
                 active hazardous materials storage and disposal facilities;
                 abandoned storage and disposal facilities; and
                 fires and explosions, other air pollution that impacts ground-
                 water.
      b)   Non-industrial sources, including:

           •    septic tanks;
           •    non-hazardous waste disposal; and
           •    agricultural fertilizers and pesticides.

3)    Types of contaminants that may be detected, including:
                 organic contaminants, including petroleum products;
                 inorganic contaminants;
                 conventional viral and bacteriological contaminants; and
                 radioactive materials.
4)    Public health impact of contamination incidents, including:

            •     immediate, acute health impacts;
            •     long-term chronic health impacts;
            •     the contaminant's persistence; and
            •     the extent of the problem.

5)    Proximity of contaminant threats to public water supply wells:

            •     in immediate vicinity of threat, or
            •     in Wellhead Protection Area.

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                                                                              Page 70
of the  contamination  threat.   Similar  evaluations can  be made  for  other types of
emergencies, depending on local priorities and available resources.

      Again, the degree to which the State becomes  involved in analyzing specific ground-
water threats in multiple, local  communities depends very much on the State's resources
and priorities as well as the structure of its WHP program.

Statewide Water Supply Replacement Assessment

      The statewide water supply assessment described  above may have identified water
systems within the State that have excess supply capacity.  It is important to include in the
plan a  summary of where  these  systems are located, the quantities of water that are
available from each system, and the means of distributing that water to other systems (for
example, by interconnections or water tanker trucks).

      In addition, State water  resource planners may be aware of potential additional
sources of water, as  yet untapped, that could be  developed in the event of an emergency,
including:

      •     Surface water sources;

      •     Undeveloped ground-water sources;

      •     Large industrial supplies;

      •     Private bottled water  suppliers; and

      •     Civil Defense agencies.

These sources should be evaluated in terms  of their requirements for treatment,  time for
development, availability of equipment to deliver the water (tank trucks, for example), or
other constraints.

State Support Resources

      In the event of water supply disruptions that exceed local response capabilities or
require specialized expertise, State resources may  be called upon to supplement local
capabilities.  State  planners  must assess the adequacy of State resources prior to an
emergency.   Four factors that should be examined include:

      •     Determining which support functions the State will provide;

      •     Determining  the  conditions under which the State will  provide
            support;

      •     Identifying  areas  of sufficiency  and deficiency  in State  support
            capabilities; and

      •     Correcting  deficiencies in State support capabilities.

      In determining what support will be provided and the conditions under which it will
be supplied, the State  may need  to strike a balance between its goal of meeting all the
local public water system needs  and  the limitations  imposed  by its budget, personnel
expertise, equipment, laboratory,  and treatment  facilities  available.  It may be useful to
survey water supply managers and local officials in order to evaluate the State's current

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                                                                              Page 71
 performance in providing such support functions.  Appendix L provides an example of a
 support functions assessment, based on specific categories of support. On the basis of the
 State's support functions  assessment, the State may need to upgrade specific support
 capabilities so that they, adequately complement local response capabilities.  Specific steps
 may involve inspection and  certification  of laboratory facilities,  contamination response
 training for purveyors and local officials, or the creation of laboratory and equipment back-
 up plans.

 4.4   WATER   SUPPLY   DISRUPTION  RESPONSE  PROCEDURES  AND  LOCAL
      PLANNING GUIDANCE

      The response procedures  of a State plan should consist of two primary types of
 information,  including:

      •    State response procedures; and

      •    Guidance for  local planning and response.

 State Response Procedures

      Initial response procedures in most water supply emergencies will of necessity take
 place at  the  local level.  Some  situations, however, will require that State resources be
 activated to support local efforts. Examples include local emergencies that require the use
 of State equipment, contamination  events that require water quality certification by State
 health department personnel, and widespread emergencies that require the State to assume
 a coordination  role over assorted local response efforts. The  plan should clearly identify
 the roles to be  played by the State and local response personnel.  This section of the plan
 will be unique to each State, determined to a large extent by  the analysis of local supply
 threats and local response capabilities.  Critical components of every State plan, however,
 include:

      •     Personnel Roster;

      •     Action  Level Response System; and

      •     Inventory of Resources.

      The  State response  sections  should include a roster of both State and Federal
 personnel who are to be contacted  in the event of a water supply emergency.  The same
 information should  be available for  use by local planners.  Exhibit 4-4 illustrates a sample
 roster derived from a State water-supply  emergency plan.   In addition,  the  plan should
 illustrate interagency relationships among the various response personnel at the State level.

      One of the most important functions of a State plan is to clearly identify  when and
how the  State will become  involved  in supporting local responses  to  water supply
disruptions. This function can be performed by developing an action-level system.  This
decision-making tool defines  appropriate types  of State  response actions  for various
contamination threats to the public water supplies, including:

      •     What       action will be taken -
                       treatment or replacement;

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                                                              Page 72
                             Exhibit 4-4

                  EMERGENCY RESPONSE CONTACTS*


    The following information indicates the type of information to be included on a
roster; the name and phone number of each contact should be provided.

    A.   STATE AGENCIES

         1.    STATE DEPARTMENT OF HEALTH SERVICES

              a.   BUREAU OF WATER QUALITY CONTROL

                  •    PRIMARY CONTACTS:

                           Emergency Response Coordinator:

                           Northern Regional Office:

                           Central Regional Office:

                  .    SECONDARY CONTACTS:

              b.   BUREAU  OF  EPIDEMIOLOGY  AND  LABORATORY
                  SERVICES

                  •    PRIMARY CONTACTS:

                           Chemical Contamination:

                           Microbiological Contamination:

                  •    SECONDARY CONTACTS:

         2.    STATE  DEPARTMENT  OF  EMERGENCY  AND  MILITARY
              AFFAIR
              (Division of Emergency Services)

                  •    PRIMARY CONTACT:

                  •    SECONDARY CONTACT:

              STATE  DEPARTMENT OF PUBLIC SAFETY:

              STATE  ATOMIC ENERGY COMMISSION

                  •    PRIMARY CONTACT:

                  .    SECONDARY CONTACT:
3.

4.
     * Derived from the Arizona State Water Supply Emergency Plan.

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                    Exhibit 4-4 (continued)




             EMERGENCY RESPONSE CONTACTS*
B.
U.S. ENVIRONMENTAL PROTECTION AGENCY - Regional Offic




     •    PRIMARY CONTACT:




     •    SECONDARY CONTACT:




     •    EMERGENCY RESPONSE COORDINATOR:




     •    EPA 24-HOUR EMERGENCY NUMBER:



OTHER LABORATORIES




     •    MICROBIOLOGICAL:




     •    CHEMICAL:
C.

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                                                                              Page
                                                                                  74
     •     When      the action is needed -
                      replacement or treatment immediately,
                      within a week, or
                      within a year;

     •     Who      (what agency, division,  or  personnel position)  is
                      responsible -
                      for replacement or treatment, and
                      for subsequent monitoring;

      •     Why      the action is being taken.

     Defining a formal action-level system as part of the  State contingency plan  has
several  benefits.  Once  established, an action-level system  can  reduce the number of
decisions to be made by State authorities when a  contamination  incident occurs; reduce
implementation time and cost; replace subjective judgments with objective answers; reduce
uncertainty for State water managers; reduce risks to public health; help inform the public
about relative risk; and increase public credibility.

      The  basic structure of an action-level system consists of a series of response tiers,
each associated with a specific type of contamination incident, a level of contamination (if
any) and  a range of responses.  The specifics of the action-level system  including the
number of response tiers, levels of contamination which trigger a set of responses, or the
types of recommended response may vary from State to State.  Appendix M outlines the
types of factors that a State should consider in developing an action-level system.

      The State plan can supplement the action level system by including specific response
procedures tailored to individual types  of events.  Appendix N  includes an example of
specific procedures for chemical contamination, drawn from New York State's guidance.

      The State plan should also include an inventory of resources available at the State
level that can be mobilized  to assist  a  local response effort.   Exhibit 2-7 and the
 accompanying  text illustrates  the type of information that should be  included  in this
 inventory.  This  information may be  obtainable from  the State Office of Emergency
 Management or Civil Defense.  In many instances, such  an inventory  can be pulled from
 an  existing State  or local  plan.

 Guidance for Local Planning and Response

       A State contingency plan for water supply should  incorporate information that will
 facilitate the development and implementation of  local response activities as well as State
 response activities, if it is to be an effective document for overall strategy guidance.  The
 State plan should include sections that address the most critical aspects of the relationship
 between State and local response activities:

        •     State delegation  of planning and response authorities  to  local
             planners;

        •     Guidance for use by local contingency planners; and

        •     State oversight of the local planning  process.

        Delegation of contingency planning  responsibility  to local planners will be specified
            O              *•*                  ___  _  ___ _ ...	.•  j.i__i. .MAVT "(%A A^fin/^tm^ T*"\T
  in a State's  Wellhead  Protection  Program.
  stimulating the planning process include:
Two methods that  may be effective for

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                                                                                Page 75
       •     Incorporating a contingency planning requirement as a condition
             of a water system operator's permit; and

       •     Conditioning approval of State grant funds to localities for water
             supply, water quality,  or public health-related  purposes on  the
             existence of an adequate contingency plan.

 Regardless of the approach used, the State should offer as much information and technical
 assistance as possible  to localities  to expedite planning and ease the demand on limited
 resources.  The State  also might conduct  a public information campaign  on contingency
 planning to  foster public support for the  preparation of contingency  plans in their
 community.

       A key function of the State plan is to encourage reliability and consistency in local
 plan development and implementation.  Through the development of standardized local
 response procedures, State planners can accomplish the following two beneficial goals:

       »    Provision of guidance for communities with limited resources  for
            local plan development; and

       •    Creation  of a  uniform response  protocol  that will facilitate
            coordination of State activities in support of .local procedures.

       State guidance  should  fulfill a local assistance  role not so  much as a model  for
 wholesale adoption by local planners, but rather by establishing criteria for the necessary
 components of a local plan.  These criteria will help to guarantee that local planners have
 evaluated the most critical components of their water system and their response capabilities
 and will also ensure that local response activities are tied  to the  State's  response plan;
 thereby facilitating communications and the activation of State resources in an emergency.
 These local components are described more fully in Chapter 2.

       Delegation and guidance is not enough to ensure that local  plans are  completed and
 will effectively provide for emergency water supplies.  The State  will  also  need  to
 coordinate and oversee the local planning process.  The task of coordination may involve
 the following activities:

       •     Establishing  a minimum set of criteria that local governments
            should follow in developing their contingency plans (e.g., essential
            plan sections);

       •     Establishing  a minimum set of criteria that local governments
            should follow in implementing  their plans (e.g., periodic  plan
            exercises, plan review following a supply disruption);

       •     Establishing the process by which the State will evaluate  local plan
            development and  implementation,  provisions  for  partial  or
            conditional plan approval (if appropriate), and the consequences
            of incomplete  or  inadequate  plans  (e.g.,  reduction  in  State
            assistance).

      As a final note, a State should work to ensure that the level of oversight undertaken
corresponds  to the degree to  which that State has  delegated  its SDWA contingency
planning responsibilities to local governments.  States that have delegated most of the
responsibility  to local governments, thus, will likely need more comprehensive oversight

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                                                                             Page 76
provisions  than States  that play a more  active role in local plan development and
implementation.

4.5 ADDRESSING PROBLEMS - FUTURE STEPS TO BE TAKEN

      During preparation of the State plan, specific response deficiencies may be identified.
These deficiencies can form the basis for a specific agenda to guide future State  water
supply.  Critical components of this agenda include measures that will address the State
role in ensuring the long-term effectiveness  of its contingency plan, including:

      •    Preventing or mitigating emergencies;

      •    Training local responders; and

      •    Reviewing and updating the plan.

Preventing or Mitigating Emergencies

      In preparing their contingency plan, State planners may identify patterns of problems
(contamination problems, shortages of treatment capacity, shortages of response equipment,
or highly constrained local budgets, to cite a few examples) in various locations throughout
the State.  Where they are common and/or significant enough, these problems provide the
basis  for preparing a specific agenda of tasks that State authorities, perhaps in conjunction
with  local officials, can undertake to prevent or  mitigate future emergencies. Such tasks
might include providing guidance on how to  deal with specific contaminants, providing new
State funding for local acquisition of response equipment or to support local planning, pr
accumulating stockpiles of critical equipment and supplies in  regional  locations around the
State.

Training Local Responders

      The  discussion in Chapter 2  emphasized the importance of appropriate training for
local responders in the specific tasks they will be responsible for  in  the event of a water
supply disruption. An evaluation of the statewide adequacy of response training for water
system  employees and others is one potential  outcome of State planners' background
information  gathering.  A logical  follow-up role for States  to play  might be to provide
funding for local response training  or to provide  such training directly through community
colleges or specialized training institutes. A direct State training role may be particularly
helpful to  smaller jurisdictions that cannot afford to provide or contract for  such training
on their own.  Even for larger  communities, State training in specialized areas such as
toxicology may be appropriate.

Reviewing and Updating the Plan

      Just as a  local plan  should incorporate  procedures for reviewing and updating
planning  assumptions and response procedures, so should State plans.   Many of the
conditions underlying a State plan when it is first prepared may change, perhaps frequently
or fundamentally.   The statewide pattern  of local ground-water supply  conditions  and
threats or  the level of local preparedness for disruption incidents are only two examples of
factors, which underlie or provide the basis for the State's  plan, that  are subject to
significant change.  Moreover, because the State plan covers a  much  larger and more
diverse territory than any single local plan, there  is great potential for conditions to change
unbeknownst to State officials.  Chapter 5 provides more information on the plan review
and update process.

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 4.6 BUILDING CONSENSUS FOR THE PLAN

       State planners can benefit from reviewing the suggestions provided in Section  2 6
 concerning procedures for building consensus in support of local plans.  While the basic
 process is the same at both  levels, two additional suggestions should be considered at the
 State  planning level.  These suggestions are based on the  necessary interactions between
 State  and local authorities in the event of an actual emergency.

       •    In testing or exercising draft State plans, the scenario(s) chosen as  the
            basis for the exercise(s) should require  State response.  The incidents
            should, for example, involve large-scale,  perhaps  regionalized  supply
            disruptions  or  contamination  from hazardous chemicals  that  require
            specialized State expertise.  Such scenarios provide the opportunity to
            test one or more local plans, the State plan, and their interaction.

       •    In structuring a process for review of the State plan, opportunities should
            be provided for local governments to comment on the plan's workability.
            Local planners and responders must be familiar and comfortable with the
            State plan if the latter is to be successful.

State planners should, of course, incorporate any other considerations that reflect their own
needs  into the review process.
      Development of an effective State response plan requires the evaluation of a broad
range of threats and a varied assortment of water supply systems. Although State planners
do not need to be as specific in tailoring responses to an individual community's needs,
they must be prepared for a wider diversity of threats than any one community will ever
face.  The most important points to keep in mind in the process are to tailor the  plan to
State needs  and  abilities;  use  all  of the resources  that  are available both  for plan
development and implementation; keep the plan simple and "user friendly;" and think out
procedures through their foreseeable consequences.

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                                                                             Page 79
                                  SECTION m
              CHAPTER 5:  REVIEWING AND UPDATING
                        LOCAL AND STATE PLANS

      Approval and completion of a ground-water supply disruption contingency plan marks
 a key milestone in improving local and State response capabilities. It is not, however, the
 end of the planning process.  This section of the TAD, which consists solely of Chapter 5,
 emphasizes the need to maintain up-to-date local and State plans and suggests specific
 techniques to accomplish this task effectively.  Most of these techniques apply to both local
 and State planning efforts.

 5.1   PLANNING IS A CONTINUOUS PROCESS

      Contingency planning is a continuous process.   As  community needs, response
 capabilities, and resources change, the local contingency plan needs to keep pace.  Likewise,
 widespread  changes in community efforts and State resource capabilities should  prompt
 revision to the State plan.  An outdated plan, be  it the local or State  plan, may  hamper
 response to a contamination incident.

      A wide variety of factors may affect a plan's timeliness, including changes in response
 agency telephone numbers and procedures, fluctuations in water demand, the quality and
 quantity of available response supplies, and shifts in land use.   Likely supply disruption
 scenarios, supply replacement options, and financial resources may also  change over time.
 Turnover of local agency personnel might necessitate the revision of a local plan's logistical
 elements,  as would shifts in  the lead agency's  organizational structure. Availability of
 services and equipment also may fluctuate as prices change, suppliers enter  or leave the
 local market, or State and Federal technical and financial support services evolve.

      Sections 2.5  and 4.5  introduced the idea  of incorporating specific procedures for
 reviewing and updating a local or State plan in the plan itself.  The focus of this chapter
 is on more detailed suggestions concerning these procedures.

 5.2    SUGGESTED PLAN REVIEW TECHNIQUES

      Contingency planning teams often disband when a plan has been approved and is
officially "on the books." However, the planning team can play  a key role in maintaining
an up-to-date, usable plan.  This job can be made easier by using a few well-tested steps
to maintain  the plan.

      •     Establish a regular plan review period, preferably either every six
           months or  annually.   Some critical components of the plan  -
           emergency notification telephone numbers,  for example - should
           perhaps be reviewed even more frequently.

      •     Test the  plan through  regularly  scheduled "table-top" and  field
           emergency exercises   (see Section  5.3).   Exercises  should be
           followed by debriefing sessions where key planners and responders
           have a chance to review how  well the plan worked and identify
           deficiencies or gaps in planning or response capabilities that need
           to be addressed.

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                                                                   Page 80
Review the plan after every significant water supply disruption
incident (see Section 5.4) so that response problems, unanticipated
difficulties, and other "lessons learned" can be incorporated into
the plan.

For a  local  plan,  review  the  plan after  making significant
modifications to the water supply system.  This will ensure that the
plan  correctly  describes  the system  and  the  implications  of
disruption events on  system components.

For a local plan, review the adequacy of the plan to cope with the
effects of proposed new developments, such as shopping centers,
industrial parks, and  subdivisions.  (Note, this review of the plan
might be integrated with a review of the development itself.)

For a local plan, review the plan after significant developments are
completed.

For a State plan, review the plan in response to significant trends
in community  response capabilities and procedures.

Publish a notice and announce a  comment period .for plan review
and revisions,  allowing the public to air  their concerns.

Maintain a list of individuals, agencies, and organizations that will
be interested in participating in the review process.

 Assign the lead responsibility for managing  the plan review and
 update process and, more generally, for stewardship of the plan to
 one agency.

 The lead agency can take steps to facilitate the review and update
 process,  including scheduling periodic  planning  team  meetings
 specifically for plan review; maintaining a list of plan holders to be
 sent any changed materials; requesting  other agencies  to closely
 review those  sections of the plan that particularly affect them;
 numbering changes   consecutively, for  ease of  tracking; using
 electronic word processing to make the process of incorporating
 changes  easier; and working with other agencies to ensure that
 contingency plan changes are integrated with other plans.

 Include both a "Record  of Amendments" sheet and a "When  and
 Where to Report  Changes" notice in the plan to facilitate both the
 reporting and sharing of changes. Exhibit 5-1 illustrates how such
 items might be incorporated into a single form.

 Clearly identify sections of the plan that are likely to be changed
 frequently.  This  can be done through  the use of colored paper,
 tabs, or other graphics techniques.

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                                   Exhibit 5-1

                  SAMPLE "RECORD OF AMENDMENTS" FORM
Notice:  Both scheduled and unscheduled official revisions to this plan should be described
and dated m the space provided below.  Reviews of the plan not resulting in amendments
should be noted as well.  Notices of review and copies of any amended sections should
then be sent to official document holders, listed in Section (          ) of this plan and
noted below.                                                    '       r   *
        Amendment^
Date
                    Copies Sent to:

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5.3 EXERCISING THE PLAN

      Short of an actual supply disruption, the best way to test the usefulness of the plan
is to exercise  it using the disruption scenarios developed in the planning process.  There
are several basic forms of plan exercises.

      •     Pull-scale  field exercises, also known as "simulations," are mock
            emergencies in which the response organizations  that would be
            involved in an  actual emergency  perform the  actions they would
            take in a  real  event.  The emphasis of such an exercise is on
            realism and time pressure as local and/or State personnel interact
            in response to  the simulated disruption scenario.  These  drills
            generally involve all response agencies and functions.

       •    Functional exercises are similar to full-scale field exercises, except
            that they usually involve testing the capabilities of only one agency
            or  response  functions.  Functional exercises might, for example,
            test the response capabilities of the local water department, the
            State  agency  responsible  for   supplying  equipment to  local
            communities during  a supply disruption, or of  those agencies
            involved in communicating with  the public.

       •    Table-top exercises provide a flexible, low-cost alternative to these
            other field-oriented exercises.  Table-top exercises require gathering
            key decision-makers from all response agencies in a room where
             they are presented with the disruption scenario by  an exercise
             facilitator.  These  exercise  "players"  then "walk" through  their
             decision-making process as realistically as possible.

       Exercises are most beneficial when followed by a meeting of all participants to review
  and critique  their performance in the exercise and identify strengths and weaknesses in the
  operation of the contingency plan.  Outside reviewers may also provide helpful feedback
  The Sc? gten the  lead in  plan  maintenance  should follow-up to make  sure that
  pTanntaJSd response deficiencies are adequately addressed  by the appropriate response
  agencies.

        Holding a successful exercise requires planning and careful execution.  Communities
  can find more detailed guidance on the use of exercises in various documents prepared by
      FedeS? Emergency Management Agency (FEMA).   These guidance materials should
      reldrty  available  through either the  local  or State  emergency  management or
        edls Igencies.  Altefnatively, FEMA's Washington or regional offices can provide
   the materials upon telephone request.

   5.4   REVIEWING  SUPPLY DISRUPTION INCIDENTS

        When a supply disruption incident does occur, a formal review of the incident helps
   the planSSg team to evaluate the effectiveness of a contingency plan. Specific suggestions
   in reviewing incidents include:

         •>    Assign lead review for incident assessment to the same agency with
              responsibility for overseeing plan review and maintenance.

         o     Conduct the review only after the emergency phase of a disruption
               is over and sufficient time has passed to permit responders to be
               objective about the incident.

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       •    Use questionnaires,  telephone interviews, and other  relatively
            formal mechanisms to obtain input from as many responders as
            possible.

       •    Convene  the  planning team to carefully review all comments,
            identify plan  and response  deficiencies, and  make appropriate
            changes in the plan.

       •    Response problems rooted not in the plan itself but in a lack of
            equipment, supplies, or financial capabilities should be documented
            and brought to the attention of the appropriate public body with
            authority for appropriating funds and acquiring response hardware.

      State plans should be reviewed following a local incident where State resources were
used or if there appears to be a trend toward a certain type of local incident.  Watching
for trends in local incidents is especially important because such trends might be addressed
more effectively at the State level than at the local level.

      Reviewing the plan following disruption incidents, building in an automatic periodic
review cycle, and the other suggestions provided in this chapter  should  help  simplify the
plan maintenance process.  This in turn will help ensure an up-to-date plan that will meet
both local, and State needs in an emergency.

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GUIDE TO GROUND-WATER SUPPLY
  CONTINGENCY PLANNING FOR
LOCAL AND STATE GOVERNMENTS
         APPENDICES

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                                   APPENDICES


 Federal Contingency Planning Requirements ......................         A.j

 List Of Workshop Participants .........................                B j

 Description Of Pilot Projects  .....................                       <-,


 Sources Of Other Information On Contingency Planning .................   £>_!

 Example Of Hazardous Material Spill Vulnerability Survey
 Checklist ............................


 List Of Sources Of Information On Hazardous Materials .................   F-l

 Short-Term And Long-Term Replacement Options  ...................      Q_I

 Potential Funding Sources . . . .............................            H1

 Example Of Emergency Notification Report ......................         j_j

 Public Education
Classification Of Water Uses And Option For Dealing With Shortages
And Water Quality Problems  ......... ....... . .........
                                                                             J~Jl
Support Functions Evaluation  ..... ......................

Action Level System  ......                                                 ,. , .
             J                ..................................   M-l

Specific Response Procedures ...........................              N .,

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                                      Appendix A

               FEDERAL CONTINGENCY PLANNING REQUIREMENTS
                           Section 1413 of the Safe Drinking
                                   Water Act of 1974

               STATE PRIMARY ENFORCEMENT RESPONSIBILITY

       Sec.  1413.(a)   For purposes  of  this title,  a  State  has primary  enforcement
 responsibility  for public water systems during any period for which the Administrator
 determines (pursuant to regulations prescribed under subsection (b)) that such State -

        (1)  has adopted drinking water regulations which are no less stringent than the
   national primary drinking water regulations in effect under section 1412(a) and 1412(b);
        (2)  has adopted and is implementing  adequate procedures for the enforcement of
   such State regulations, including conducting such monitoring and making such inspections
   as the Administrator may require by regulation;
        (3)  will keep such records and make such reports with respect to its activities under
   paragraphs (1) and (2) as the Administrator may require by regulation;
        (4)  if it permits variances  or exemptions, or both, from the requirements of its
   drinking water regulations which meet the requirements of paragraph (1), permits  such
   variances and exemptions under conditions  and in a manner which is not less stringent
   than the conditions under, and the manner in, which variances and exemptions may be
   granted under sections 1415 and 1416; and
        (5)   has adopted and can implement an adequate plan for the provision of safe
   drinking water under emergency circumstances.

   (b)(l) The Administrator shall, by regulation (proposed within 180 days of the date of
 the  enactment of this title), prescribe the manner in which a State may apply  to  the
 Administrator for a determination that the requirements of paragraphs (1), (2)  (3) and (4)
 of subsection  (a) are  satisfied with respect  to  the State,  the  manner in  which  the
 determination is made, the period for  which the determination will be effective and  the
 manner in which the Administrator may determine that such requirements are no  longer
 met.  Such regulations shall require that before a determination of the Administrator  that
 such  requirements are met, or are no  longer met with  respect to a State may become
 effective, the Administrator shall notify such State of the determination  and the reasons
 therefore and shall provide an opportunity for public hearing on the determination. Such
 regulations shall  be promulgated  (with such  modifications as  the Administrator  deems
 appropriate) within 90 days of the publication of the proposed regulations in the Federal
 Register.  The Administrator shall promptly notify in writing the chief executive officer of
 each  State of the promulgation of regulations under this paragraph.  Such notice shall
 contain a copy of the regulations and shall specify a State's authority under this title when
 it  is  determined to have primary enforcement  responsibility for public water systems.
  (2)  When an application is submitted in accordance with the Administrator's regulations
 under paragraph (1), the Administrator shall  within 90 days  of the date on which such
application  is  submitted (A) make the  determination  applied  for, or (B)  deny  the
application and notify the applicant in writing of the reasons for his denial.

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                                                                            Page A-2
                               Appendix A (continued)

               FEDERAL CONTINGENCY PLANNING REQUIREMENTS
                        Section 205 of the Safe Drinking Water
                               Act Amendments of 1986

      STATE PROGRAMS TO ESTABLISH WELLHEAD PROTECTION AREAS

    The Safe Drinking Water Act is amended by adding the new section 1428,  as follows:

SEC.  1428. STATE PROGRAMS TO ESTABLISH WELLHEAD PROTECTION AREAS

          (a)  State Programs. - The Governor or Governor's designee of each State shall,
    within 3 years of the date of enactment of the Safe Drinking Water Act Amendments
    of 1986 adopt and submit to the Administrator a State program to protect wellhead
    areas within their jurisdiction from contaminants which may have any adverse affect on
    the health of persons.  Each State program  under this section shall, at a minimum --

                (1) specify the duties of State agencies, local governmental entities, and
          public water supply systems with respect to the development and implementation
          of programs required by this section;                               .,*.,,
                (2) for each wellhead, determine the wellhead protection area as defined
          in subsection (e) based on all reasonably available hydrogeologic information on
          ground water flow, recharge and discharge and other information the State deems
          necessary to adequately determine the wellhead protection area;
                (3)    identify within  each   wellhead  protection  area  all potential
           anthropogenic sources of contaminants which may have any adverse effect on the
           health of persons;                                        ,.,•«.
                 (4) describe a program that contains, as appropriate, technical assistance,
           financial assistance, implementation of control measures, education, training, and
           demonstration projects to protect the water supply within wellhead protection
           areas from such contaminants;
                 (5)  include contingency plans for the location and provision  of alternate
           drinking water supplies for each public water system in the event of well or
           wellfield contamination by such contaminants; and
                 (6)  include a requirement that consideration be given to all potential
           sources of such contaminants within the expected wellhead area of a new water
           well which  serves a public water  supply system.
           (b)  Public Participation. - To the  maximum extent possible, each State shall
     establish procedures, including but not  limited to the establishment of technical and
     citizens' advisory committees, to encourage the public to participate in developing the
     protection program for wellhead areas.  Such  procedures  shall  include notice and
     opportunity for public hearing on the State program before it is  submitted to the
     Administrator.
            (c)  Disapproval. —
                  (1)   In General. - If, in the judgment  of the Administrator, a  State
            program (or portion thereof, including the definition of a wellhead protection
            area), is not adequate to protect public water systems as required by this section,
            the Administrator shall disapprove such program (or portion thereof). A State
            program developed pursuant to subsection (a) shall be deemed to  be adequate
            unliss the Administrator determines, within 9 months of the receipt of a State
            program, that such program (or  portion thereof) is inadequate for the purpose
            of protecting public water systems as required by this section from contaminants

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                                                                            Page A-3
                              Appendix A (continued)

             FEDERAL CONTINGENCY PLANNING REQUIREMENTS
                      Section 205 of the Safe Drinking Water
                             Act Amendments of 1986
                                    (continued)

        that may have any adverse effect on the health of persons.  If the Administrator
        determines that a proposed State program (or any portion thereof) is inadequate,
        the Administrator shall submit a written  statement  of the  reasons for such
        determination to the Governor of the State.
              (2)  Modification and Resubmission. — Within 6 months after receipt of
        the Administrator's written notice under paragraph (1) that any proposed State
        program (or  portion  thereof)  is inadequate, the Governor  or Governor's
        designee, shall modify the program  based  upon the recommendations of the
        Administrator and resubmit the modified program to the Administrator.
        (d)  Federal Assistance. - After the date 3 years after the enactment of this
 section, no State shall receive funds authorized to be appropriated under this section
 except for the purpose of implementing the program and requirements of paragraphs
 (4) and-(6) of subsection (a).
        (e) Definition of Wellhead Protection Area. - As used in this section, the term
 'wellhead protection area' means the  surface and subsurface area surrounding a water
 well or wellfield,  supplying a public water system, through  which contaminants are
 reasonably likely to move toward and reach such water well or wellfield.  The extent
 of a wellhead protection area, within a State, necessary  to provide protection from
 contaminants which may have any adverse effect  on the health of persons is to be
 determined by the State in the program submitted under subsection (a). Not later than
 one year after the enactment of the Safe Drinking Water Act Amendments of 1986, the
 Administrator shall issue technical guidance which States may use in making such
 determinations.  Such guidance may reflect such  factors as the  radius of influence
 around a well or wellfield, the depth  of drawdown of the water table by such well or
 wellfield at any given point,  the time or rate of travel of various  contaminants in
 various hydrologic conditions, distance from the well or wellfield,  or other  factors
 affecting the likelihood  of contaminants reaching the well or wellfield, taking into
 account available  engineering pump  tests or comparable data, field reconnaissance,
 topographic  information, and the geology  of the formation in  which the well or
 wellfield is located.
       (f)  Prohibitions. ~
             (1)    Activities  Under  Other Laws. - No funds  authorized  to  be
       appropriated under this section may be used to support activities authorized by
       the Federal Water Pollution Control Act, the Solid Waste Disposal Act, the
       Comprehensive Environmental Response, Compensation, and  Liability Act of
       1980, or other sections  of this  Act.
             (2)  Individual Sources. - No funds authorized to be appropriated under
       this section  may be  used to bring individual  sources of contamination into
       compliance.
       (g)   Implementation. - Each State  shall  make every reasonable  effort to
implement the State wellhead area protection program under this section within 2 years
of submitting the  program  to the  Administrator.   Each State shall submit to the
Administrator a biennial status report describing the State's progress in implementing
the program.  Such report shall include amendments to the State program for water
wells sited during the biennial period.

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                                                                           Page A-4
                             Appendix A (continued)

            FEDERAL CONTINGENCY PLANNING REQUIREMENTS
                     Section 205 of the Safe Drinking Water
                            Act Amendments of 1986
                                   (continued)

       (h)  Federal Agencies. - Each department, agency, and instrumentality of the
executive,  legislative,  and  judicial  branches  of the Federal  Government  having
jurisdiction over any potential source of contaminants identified by a State program
pursuant to the provisions of subsection (a)(3) shall be subject to and comply with all
requirements of the State program developed according to subsection (g)(4) applicable
to such potential source of contaminants, both .substantive and procedural, in the same
manner, and to the same extent, as any other person is subject to such requirements,
including  payment of reasonable charges and  fees.   The President may exempt any
potential source under the jurisdiction of any department, agency, or instrumentality in
the executive branch if the President  determines it to be in the paramount interest of
the United States  to do so.  No such  exemption shall be granted due to the lack of an
appropriation unless the President shall have specifically requested such appropriation
as part of the budgetary process and  the Congress shall have failed to make available
such requested appropriations.
       (i)  Additional Requirement. -                                             ,
             (1)  In General. - In addition to the provisions of subsection (a) of this
       section, States in which there are more than 2,500 active wells at which annular
       injection is used as of January 1, 1986, shall include in their State program a
       certification that a State program exists and is being adequately enforced that
       provides protection from contaminants which may have any adverse effect on the
       health of persons and which are  associated with the annular injection or surface
       disposal of brines  associated with oil  and  gas production.
             (2)  Definition.  - For purposes of this subsection, the term 'annular
       injection' means the reinjection  of brines associated with the production  of oil
       or gas between the production and  surface casings of a conventional oil or gas
       producing  well.
              (3)  Review. - The Administrator shall conduct a review of each program
       certified under this subsection.
              (4)  Disapproval. - If  a  State fails to include the certification required
       by this subsection or if in the judgment of the Administrator the State program
       certified  under  this  subjection  is  not  being  adequately  enforced,  the
       Administrator shall disapprove the State program submitted under subsection (a)
       of this section.
        (j) Coordination With Other Laws.  - Nothing in this section shall authorize
 or require any department,  agency, or other instrumentality of the Federal Government
 or State or local government to apportion, allocate or otherwise regulate the withdrawal
 or beneficial use  of ground or surface waters, so as to abrogate or modify any existing
 rights to  water  established  pursuant  to  State  or  Federal  law,  including interstate
 compacts.

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                                                                            Page A-S
                               Appendix A (continued)

              FEDERAL CONTINGENCY PLANNING REQUIREMENTS
                      Section 301 of the Emergency Preparedness
                      and Community Right-to-Know Act of 1986
                         (EPCRA, also known as Title III of
                           the Superfund Amendments and
                            Reauthorization Act of 1986)

          SUBTITLE A:  EMERGENCY PLANNING AND NOTIFICATION

                  Section 301 - Establishment of State Commissions,
                       Planning Districts, and Local Committees

   (a)    ESTABLISHMENT OF STATE EMERGENCY RESPONSE COMMISSIONS. -
 - Not later than six months after the date of the enactment of this title, the Governor of
 each State shall  appoint  a  State emergency response commission.  The  Governor may
 designate as  the  State emergency response commission one  or more existing emergency
 response organizations that are State-sponsored or appointed. The Governor shall, to the
 extent practicable, appoint persons to the State emergency response commission who have
 technical expertise in the emergency response field.   The State emergency  response
 commission shall appoint  local emergency planning committees under subsection (c) and
 shall supervise and coordinate the  activities  of such committees.  The State emergency
 response commission shall establish procedures for receiving and processing requests  from
 the public for information under section 324, including tier II information under section
 312.  Such procedures shall include the designation of an official to serve  as coordinator
 for information.   If the Governor  of any State does not designate  a State emergency
 response commission within such period, the Governor shall operate as the State emergency
 response commission until the Governor makes such designation.
  (b)    ESTABLISHMENT OF EMERGENCY PLANNING DISTRICTS. - Not  later
 than  nine months after the date of the enactment of this title, the State emergency
 response commission shall designate emergency planning districts in order to  facilitate
 preparation and  implementation of emergency plans.   Where appropriate,  the State
 emergency response   commission  may designate  existing political  subdivisions or
 multijurisdictional planning organizations as  such districts. In emergency planning areas
 that involve  more than one State, the State emergency response  commissions of all
 potentially affected States  may designate emergency planning districts and local emergency
 planning committees by agreement.   In making such designation, the State emergency
 response commission  shall indicate which facilities subject to  the requirements of this
 subtitle are within such emergency planning district.
  (c)     ESTABLISHMENT OF LOCAL EMERGENCY PLANNING COMMITTEES. -
 - Not later than 30 days after designation of emergency planning districts  or 10 months
after the date of the enactment of this title, whichever is earlier, the State emergency
response commission shall appoint members of a local emergency planning  committee for
such  emergency  planning district.    Each  committee shall include, at  a minimum,
representatives from each of the following groups or organizations: elected State and local
officials; law enforcement,  civil defense, firefighting, first aid, health, local environmental,
hospital, and transportation personnel; broadcast and print media; community groups; and
owners  and operators  of  facilities subject to the requirements of this subtitle.   Such
committee shall appoint a chairperson and shall establish rules by which the committee
shall function.  Such rules shall include provisions for public notification  of committee
activities, public meetings to discuss the emergency plan, public comments, response to such
comments by the committee, and distribution  of the emergency plan. The local emergency

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r
                                                                                                 Page A-6
                                                    Appendix A (continued)

                                    FEDERAL CONTINGENCY PLANNING REQUIREMENTS
                                           Section 301 of the Emergency Preparedness
                                           and Community Right-to-Know Act of 1986
                                                          (continued)

                       planning committee shall establish procedures for receiving and processing requests from
                       the public for information under section 324, including tier II information under section
                       312. Such procedures shall include the  designation of an official to serve as coordinator
                       for information.                                         >
                         (d)    REVISIONS. - A  State  emergency  response commission  may revise its
                       designations and appointments under subsections (b) and (c) as it deems  appropriate.
                       Interested persons may petition  the State emergency response commission to modify the
                       membership of a local emergency planning committee.

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                                                                                         Page B-l
                                           Appendix B

                              LIST OF WORKSHOP PARTICIPANTS
       The following Federal, State, and local water supply and emergency response experts participated
 in a contingency planning workshop held in Washington, D.C. on January 27 and 28, 1988.  These officials
 might  be able to offer valuable insight to State and local governments undertaking contingency planning
 efforts of their own.
Jon Beekman, Manager
Division of Environmental Management
Whitman & Howard, Inc.
45 William Street
Wellesley, Massachusetts  02181
(617) 237-5000

Scott Cunningham, Washington Representative
Federal Relations Department
Union Carbide Corporation
1100 Fifteenth Street, N.W.
Washington, D.C.  20005
(202) 872-8555

Rodney DeHan, Assistant Bureau Chief
Bureau of Groundwater Protection
Florida Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee,  Florida  32301
(904) 488-3601

Russell Ellison, Senior Geologist
Virginia Water Control Board
P.O. Box 11143
Richmond, Virginia 23230
(804) 367-6350

James Feuss, Public Health Director
Cortland County Health Department
60 Central Avenue
P.O. Box 5590
Cortland, New York  13045
(607) 753-5036

Charles Glore, Associate Engineer
Mobil Research and Development Corporation
Paulsboro Research Lab
Bellingsport  Road
Paulsboro, New Jersey  08066
(609) 423-1040
 Larry Graham, Training Specialist
 States Program Division
 Office of Drinking Water
 U.S. EPA
 401 M Street, S.W.
 Washington, D.C.  20460
 (202) 382-7593

 Paul Guthrie, Director
 State and EPA Relations
 Office of Community and Intergovernmental
  Relations
 U.S. EPA
 401 M Street, S.W.
 Washington, D.C.  20460
 (202) 382-4461

 Doug (Dusty) Hall, Environmental Protection
  Manager
 Dayton Department of Water
 101 West Third Street
 Dayton, Ohio  44502
 (513) 443-3734

 Sam Harper, Field Supervisor
 Operation Section
 Bureau of Water Quality Management
 Pennsylvania Department of Environment
  Resources
 121 South Highland Avenue
 Pittsburgh, Pennsylvania  15206
 (412) 645-7166

John Hroncich, Sanitary  Engineer
Hackensack Water  Company
200 Old Hook Road
Harrington Park, New Jersey  07640
(201) 767-9300

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                                                                                        Page B-2
                                    Appendix B (continued)

                             LIST OF WORKSHOP PARTICIPANTS
Donald A. Kuntz, Director
Environmental Engineering Division
West Virginia Office of Environmental Health
  Services
1800 Washington Street
West Charleston, West Virginia  25305
(304) 348-2981

Robert Mendoza, Chief
Ground-Water Management Section
US. EPA - Region I
JFK Federal Building, Room 2203
Boston, Massachusetts 02203
(617) 565-3600

Richard Mitzelfelt, Chief
Groundwater Bureau
New Mexico Environmental Improvement Division
P.O. Box 968
Sante Fe, New Mexico  87504
(505) 827-2919

George Moein, Chief
Emergency Response and Control Section
U.S. EPA - Region IV
345 Cortland Street, N.E.
Atlanta,  Georgia  30365
(404) 347-3931

Glenn Moon, Director
Valley Park  Water Department
320 Benton Street
Valley Park, Missouri 63088
(314) 225-5171

Jennifer  Orme, lexicologist
Health Effects Branch
Office of Drinking Water
U.S. EPA
401 M Street, S.W.
Washington, D.C. 20460
(202) 382-7586
Rick Otis, Policy Analyst
Office of Assistant Administrator for Solid Waste
  and Emergency Response
U.S. EPA
401 M  Street, S.W.
Washington, D.C. 20460
(202) 382-2203

Bill Price, Section Chief
Public  Drinking Water Program
Missouri Department of Natural Resources
P.O. Box 1368
Jefferson City, Missouri  65102
(314) 751-5331

Velma  Smith, Director
Groundwater Project
Environmental Policy Institute
218 D  Street, S.E.
Washington, D.C. 20003
(202) 544-2600

Edith Tanenbaum, Bi-County Planning
  Coordinator
Long Island Regional Planning Board
H. Lee Dennison Building, 12th Floor
Veterans Memorial Highway
Hauppauge, New York 11788
(516) 360-5195

Dr. Raymond Thron, Director
Division of Environmental Health
Minnesota Department of Health
717  Delaware Street, S.E.
P.O. Box 9441
Minneapolis, Minnesota 55440
(612) 623-5320

David  Venekamp, City Administrator
City Hall
239  Central Avenue
Long Prairie, Minnesota  56347
(612) 732-2167

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                                                                                     PageB-3
                                    Appendix B (continued)

                            LIST OF WORKSHOP PARTICIPANTS
Sam Wade, Director of Professional Services
National Rural Water Association
P.O. Box 1428
2915 South 13th Street
Duncan, Oklahoma  73534
(405) 252-0629
Doug Yoder, Assistant Director
Dade County Environmental Resources
  Management Department
111 Northwest 1st Street, Suite 1310
Miami, Florida  33128
(305) 375-3376

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                                                                             Page C-l
                                    Appendix C

                              EPA PILOT PROJECTS
      This appendix briefly describes the results of five pilot projects that EPA initiated in
order to learn more about the practical realities of contingency planning.

                                  Tucson, Arizona

      Tucson is a large, well-known city of the desert Southwest and like  Phoenix, its
neighbor to the north, is a popular place to live for young and old alike. Lying within the
Sonoran  Desert, Tucson  has a climate  characteristic of the lower  elevations of  the
southwestern United States, controlled largely by the presence of extensive mountain ranges
surrounding the city, and  long distances from major bodies of water.  The area enjoys a
mild, dry winter  and  has  a long,  hot  season lasting  from April  through  October.
Precipitation averages less than 12 inches per year, and almost half of this occurs during
the summer months.    This period provides  isolated  but violent thunderstorms, which
generate flash flooding of considerable proportions.

      Tucson's  1985 population was recorded  at approximately 634,000 persons, and is
projected to reach just over 1  million by the turn of the century.  With this projected
increase,  the demand for  water and related services is on the rise.  Tucson is  currently
aiming for "safe yield"  status in ground-water management, which  means  reducing  the
amount of water withdrawn so as not to exceed the natural and artificial recharge capacity
of the aquifer to replenish itself. These withdrawals or "overdrafts" are currently the result
of an increased amount of land dedicated to agriculture and copper mining activity.

      Most ground water  in the Tucson area is of excellent quality, but highly variable in
type.  Some areas do exist where ground-water quality is poor, but these areas are not used
for public drinking water supplies. Tucson's ground-water reserves are relatively deep, with
average depth-to-ground water of about 200 feet. In some parts of the area, water levels
have  dropped more than 100 feet since 1940, primarily  due to increased ground-water
demand.  In order to reduce this continuing dependency on ground-water reserves, Tucson
plans to receive water from the massive Central Arizona Project (CAP), which will bring
water by surface canal from the Colorado River, by way of Phoenix.  This additional water
supply, slated  for  delivery in the early 1990's, will allow reduced dependence on ground
water as  the only source of drinking water, and will  allow the surrounding aquifers to
recharge naturally over the first 2 to 3 years after CAP  water is made available to Tucson.

      The extensive depth-to-ground water and the very long time of travel combine to de-
emphasize the importance of contaminant spills or  releases in comparison to the threat of
physical disruption of public water supplies and services.  Tucson has experienced damage
and disruption of public water supplies in the past as a result of flash  flooding within their
wellfields, and intentional thefts and vandalism of pumping and distribution equipment
For these reasons, Tucson became very interested in developing a  pilot contingency plan
as part of EPA's Wellhead Protection Program.

      The  Pima Association  of Governments  (PAG),  headquartered in  Tucson, was
instrumental in orchestrating cooperative efforts among Pima County, the City of Tucson,
and individual private water providers within the Tucson metropolitan area.  Before PAG
took the lead, ambiguity and confusion existed between the State, county, local, and private
interests  in  terms of the  benefits and responsibilities  in developing a contingency plan.
Through skillful networking and cooperative effort,  PAG was able to  bring  most of the
major water providers in  the Tucson area to agreement and participation  in  the Water

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                                                                             Page C-2
                               Appendix C (continued)

                               EPA PILOT PROJECTS


                             Tucson, Arizona (continued)

Supply Interruption Contingency Planning Committee, the formal workgroup developing
the plan.   This workgroup participated  in  meetings with State, county, local, and EPA
Regional  and Headquarters personnel to  help draft the contingency plan,  which was
specifically designated to meet the unique needs of Tucson's water service areas.

      Without strong local leadership,  the development of a contingency plan for Tucson,
Arizona would not have taken place.  The  number of smaller water providers were very
reluctant to devote time and resources to developing the plan, because they did not foresee
any significant benefit to them as smaller companies. The major water provider in Tucson
was likewise reluctant from the historical point of view, because it had always been able to
handle any interruptions  in supply  or service with relatively little outside assistance  or
disruption in routine. By illustrating the potential benefit to all water providers, regardless
of size or  service area, PAG was able to pool the resources, knowledge and expertise of the
largest as well as the smallest of Tucson's water providers, thus facilitating the development
of the area's  first water supply contingency  plan.
                                   Oakley, Kansas

      Oakley is a small community located in western Kansas, about 70 miles from  the
Colorado bbrder.  The  current population is approximately 800 people and has remained
fairly constant over the last decade.  The community is served by rail and interstate highway
systems and is primarily an agricultural community with sustained production of cereal
grains (wheat).  Some  oil  wells are located in the Oakley area, with 21 active oil wells
currently pumping within Oakley's defined Wellhead Protection Areas.  Population changes
as a result of commercial or industrial development are not expected in  the near future.

      Oakley is totally  dependent on ground  water as its only source of drinking water.
Oakley's water supply system consists of 6 on-line wells, with one approved well to be
completed.  Each of the wells can be independently operated in the system and turned on
or off at will.  The operation of the system is overseen by the city superintendent who has
historically  maintained  a  more  or  less  even  pumping  regime,  allowing adequate
opportunities for well and pump maintenance when necessary. July is  typically the highest
use month, with February the lowest.

      With agriculture the primary activity in  and around Oakley, and with the existence
of actively pumping oil wells, several potential pathways of ground-water pollution  are
possible.  Underground disposal wells, brine tank batteries, underground transmission lines
and storage tanks all pose potential threats to Oakley's drinking water supplies drawn from
ground-water reserves.  A  landfill which has existed for years without monitoring, lining,
or attempts at  leachate control  also  creates potential threats.   Agricultural chemicals
(pesticides and  fertilizers)  are heavily used throughout the  area  and contribute a well-
defined subset of potential contaminants to ground-water reserves in the area.  Above-
ground and underground storage tanks containing petroleum products are numerous in the
area and have maintenance histories of varying  reliability. Grain elevators  in the immediate
area are a potential source of VOC contamination from fumigation  activities connected
with cereal grain storage.

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                                 Appendix C (continued)

                                EPA PILOT PROJECTS


                               Oakley, Kansas (continued)

       Impetus for the development of a contingency plan for Oakley originated at the State
  level, with Kansas' Northwest Ground Water Management District No. 4 directly involved.
  The variety of potential ground-water contaminants, the small number of wells providing
  public water, and the total dependence of the city on ground water for its drinking water
  supplies all factored into the selection of Oakley as a  candidate for a Contingency Pilot
  Project location. Coordination at the local  level took place within the town council with
  the mayor as lead.  The Office of City Administrator, which had existed but had not
  previously been  occupied, has now been designated as  the local lead, and the incumbent
  serving in this position must now assume the lead role.

       The process of developing a contingency plan for Oakley, Kansas is currently inactive
  because of a transfer of the lead role from the mayor to the City Administrator.  Only after
  the new City Administrator has become familiar with the essentials of the plan and the new
  members of the  town council briefed as to the plan's long-term  benefits can the planning
 process begin  again.
                               Sioux Falls, South Dakota
                                           >
      Sioux Falls, South Dakota is located in the southeastern corner of the state and is
 approximately 230 miles  southwest of Minneapolis/St. Paul, Minnesota.  The city has a
 population of roughly 96,000 people, and relies almost totally on ground water for public
 drinking water supplies, mostly drawn from the Big Sioux Aquifer. This aquifer is the most
 accessible, the most used, and the most susceptible to contamination. Other aquifers are
 located near  the city, but  are much  less accessible and  unsuitable for development as
 primary drinking water supplies. Depth to ground water in the Sioux Falls area is generally
 less than 20 feet and high-capacity wells may yield over 1,000 gallons per minute.  The
 relatively shallow depth to ground water and potentially high capacity well yields make this
 aquifer a naturally attractive and logical choice for ground-water withdrawal to satisfy public
 water supply needs.

      Municipal growth within the Sioux Falls area is increasing and with it the demand
 for water supplies and services.  The city currently uses about 16.3 million gallons of water
 a  day on  an average basis.   Along  with  this growth, the potential for ground-water
 contamination resulting from man's activities is likewise increasing.  Sioux Falls is a central
 warehousing and distribution point for materials routinely used by  the agribusiness complex
 and is served by rail  and highway routes which deliver pesticides, fertilizer, petroleum
 products,  organic solvents and commercial industrial metals to the area for  consumption
 and distribution.  Agricultural waste impoundments, meatpacking plants, road salt storage
 piles, and urban runoff also  compound the potential ground-water contamination problem
 in this area.

      In April 1987, Sioux Falls experienced a break in a gasoline transmission pipeline
which occurred within a half mile  of  one  of the city's major public water supply wells.
Although the pipeline company worked swiftly with the South Dakota Department of Water
and Natural Resources and  the City of Sioux Falls to correct the problem,  the incident
demonstrated the potential for extensive ground-water contamination and significant damage
to the .municipal well field.  Following this incident, the City of Sioux Falls accelerated

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                                                                            Page C-4
                              Appendix C (continued)

                              EPA PILOT PROJECTS


                        Sioux Falls, South Dakota (continued)

plans for  the development of a contingency  plan  to respond to similar threats to  their
public water supplies.  An active representation at the local level, including introduction
of a bill containing provisions for a comprehensive Wellhead Protection Program, including
contingency planning, helped to facilitate the development of Sioux Falls contingency plan.

      The "real life"  experience of having to respond to an imminent threat  to public
drinking water supplies from a contamination  incident goes a long way towards accelerating
the development of a local contingency plan.  However, without significant support at the
local level from municipal program 'Offices (Health Department, Fire and Rescue, Civil
Defense etc), the process is slow and often difficult to orchestrate. The added support and
exposure  to the  legislative  process  at the state  level  provided  by a  local elected
representative was instrumental in focusing the importance of developing contingency plans
at the local level for the City of Sioux Falls,  South Dakota. Once the desire to establish
a contingency  plan  for  Sioux Falls was firmly entrenched and the  process begun, the
neighboring community  of Brookings,  South  Dakota, some 60 miles north  of Sioux Falls
and dependent on the same aquifer for  its public water supplies, began investigating the
process of developing its own contingency plan.
                                  Corning, New York

      The City of Corning is located in south-central New York on the Chemung River,
 a major branch of the Susquehanna River.  The City relies completely on ground-water
 supplies because  surface  water  filtration and treatment is  thought to be  prohibitively
 expensive   Up to one-third of the municipal water supply is used by Corning Glass Works;
 the remainder meets the domestic needs of the city's 13,000 residents (1980  census).

      The major  water supply and protection problems  which the contingency plan must
 consider are a vulnerable aquifer system, a limited storage and excess pumping capacity, and
 the confinement  of storage capacity to one side of the river.  Additionally, Corning is
 developing its contingency plan in the context of pre-existing State requirements and local
 emergency planning efforts. New York State's Water Supply Emergency Plan statutes which
 require all community systems with gross revenues in excess of  $125,000 to prepare and
 submit a plan to  the State Department of Health by December 31st, 1990.  The city would
 also like to integrate the plan  into the broader context of regional watershed  planning
 efforts. The City's Public Works Department, responsible for water supply  protection, is
 a small department with limited resources.

       The regional aquifer system consists of a near-surface sand  and gravel aquifer in
 hydraulic connection with the surface waters and a deeper semi-confined aquifer.  Heavy
 pumping  in the  region has led to water-table  declines and pumping-induced infiltration
 from surface waters now is an important source of aquifer  recharge.  Up to 70% of the
 discharge from municipal wells may be from induced  surface water recharge in the well
 vicinity   Although municipal and industrial wells are generally screened in the  deeper
  aquifer  this  aquifer is  recharged through "windows"  in the confining layer as well as
  lelkage   Thus,  both aquifers  are vulnerable  to pollution from surface  and subsurface
  contamination sources, as well as contaminated surface waters, and two of the city's nine
  municipal wells have already been closed due to TCE contamination.  The contamination

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                                                                              fage C-5
                                Appendix C  (continued)

                               EPA PILOT  PROJECTS


                            Corning, New York (continued)

 sources  have not been conclusively identified and there is  a clear and urgent need  for
 source identification and management in the  wellhead areas.

       The total pumping capacity of Coming's municipal wells is roughly twice that of the
 3.5 million gallon per day (gpd) demand. Storage capacity is about 5.3 mgd - about one-
 and-a-half days supply. Corning is  considering increasing its storage capacity as part of its
 long-range contingency planning efforts. In addition to the limited storage capacity, long-
 range emergency planning must consider how to alleviate the problem of storage confined
 to one side of the river.

       One lesson learned in the process of undertaking a contingency plan for Corning,
 New York, has  been that increased coordination is needed between Steuben County's
 Emergency Planning efforts and the Corning Fire Department's Emergency Response Plan.
 In terms of current  preparedness for  immediate response  to  short-term emergencies,
 Corning benefits from the existing New York State Emergency Planning and Response
 Program which has well-defined guidelines and includes regionally distributed stockpiles of
 materials and equipment.  On the other hand, Coming's efforts in developing a contingency
 plan have been hampered by the difficulties of interagency coordination, and by the limited
 fiscal and manpower resources of a relatively  small municipal agency.
                                 Jackson, Tennessee

      The City of Jackson, Tennessee receives its public water supply from the Jackson
Utility Division, a combined public utility, providing water and sewer service, power and
light to the City.

      The Water Department is totally served by ground-water wells and supplies 22,000
service  connections  and a population of 60,000 persons.  The system  is comprised  of
nineteen deep wells which feed through two water treatment plants.  The treatment plants
provide aeration, disinfection, stabilization, fluoridation, and filtration.

      Jackson has completed it's emergency response plan and is currently in the process
of a routine revision to update names, addresses, and telephone numbers. Jackson chose
to structure their plan differently from local emergency response plans.  Their plan is
organized  to provide  detailed resource  information to  those responding to emergency
conditions.  For example,  the report  reproduced  with different colored pages  for each
section to allow for quick reference during an emergency.  The plan differentiates between
internal   resources  (i.e.,   personnel,  equipment,   materials,  storage  facilities  and
communications) from external resources.   The section on external resources identifies
contractors, government  agencies, other water utilities, parts and repair  services, private
water suppliers and media contacts.

      Jackson Utility District (JUD) views their contingency plan as not only a document
to turn to in the event of an emergency, but also as an educational/training document for
new employees.  For  the  first time the District has a complete  compendium of their
systems, resources, and potential problem areas.

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                                                                           Page C-6
                              Appendix C (continued)

                              EPA PILOT PROJECTS
                          Jackson, Tennessee (continued)

     Jackson's efforts to prepare an emergency response plan were prompted mainly by
the State of Tennessee's requirement that all public water suppliers prepare an emergency
operation plan. The Rules of the Tennessee Department of Health and Environment state
that"  all community water systems shall prepare an emergency operations plan in order
to safeguard the water supply and to alert the public of unsafe drinking water in the event
of natural or man-made disasters."              -e                         ...

     The plan that is currently prepared for Jackson provides an excellent system reference
document and in the event of an emergency,  can be a valuable aid in determining the
appropriate response.

     JUD assumed responsibility  and managed  the  entire process  of  producing an
emergency  response plan. Strong leadership and a sense of need directed the efforts and
assured success. Staff support was  available to direct to this effort and in a few months
time the entire document was completed.

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                                          Appendix D

                  SOURCES OF INFORMATION ON CONTINGENCY PLANNING
                                  FEDERAL PUBLICATIONS
                    Title
 Protection of Public Water Supplies from Ground-
 Water Contamination  (Basic Information  on
 hydrogeology and water treatment options)

 Hazardous Materials Emergency Planning Guide
 NRT-1 (General Planning Model)


 Emergency Response Guidebook
                                                                 Available From
  U.S. EPA, 401 M Street, S.W.
  Washington, D.C. 20460 (September 1985)


  National Response Team
  GWER/12, 2100 Second Street, S.W.
  Washington, D.C. 20593 (March 1987)

  Materials Transportation Bureau
  U.S. Department  of Transportation
  Washington,  D.C.  20590 (1984)
                         STATE PLANS AND OTHER PUBLICATIONS
                    Title

 Memorandum:    Groundwater  Contamination
 Remediation Strategy
 Emergency Planning and  Response:  A Water
 Supply Guide for the Supplier of Water
Drinking Water Supply Emergency Plan
Standard   Procedures   for   Drinking   Water
Emergencies

Memo on Guidelines for Use of Tank Trucks
                 Produced by

 New York State Department of Environmental
 Conservation
 50 Wolf Road, Albany, New York  12233-3505
 (April 1987)

 New York State Department of Health
 Bureau of Public Water Supply Protection
 Corning Tower, Rockefeller Empire
 State Plaza, Albany, New York  12237
 (January 1984)

 State of Ohio, Office of Public Water Supply
 Environmental Protection Agency, Box 1049
 Columbus, Ohio  43216, (614) 466-8307
 (September 1977)

 Office of Emergency Services
State of West Virginia (October 1981)

Department of Natural Resources
State of Wisconsin, Box 7921
Madison, Wisconsin 53707 (undated)

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                                  Appendix D (continued)

                SOURCES OF INFORMATION ON CONTINGENCY PLANNING
                          NON-GOVERNMENTAL PUBLICATIONS
                   Title
Emergency Procedures Handbook
Video Teleconference on Emergency Planning for
Potable Water Supplies


Handbook for Public Notification During Drinking
Water Contamination Events
                Produced by

American Water Works System (1979)
1010 Vermont Avenue, N.W.
Suite 810
Washington, D.C.  20005-4994

U.S.  EPA,  Federal  Emergency  Management
Agency, U.S. Army Corps of  Engineers,  and
American Water Works Association (June, 1987)

Virginia Water Project, Inc.
P.O. Box 2868
Roanoke,.Virginia  24001
(703) 345-6781

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                                           Appendix: E     ,

       EXAMPLE OF HAZARDOUS MATERIAL SPILL VULNERABILITY SURVEY CHECKLIST7


       The following checklist, adapted from the American Water Well Association Handbook:  Hazardous
 Materials Spills Emergency Handbook,  has been provided to assist the supplier of water in identifying
 problem areas and corrective actions that can be taken to mitigate emergencies associated with hazardous
 material spills.  Maps showing exact locations of railroad crossings, highways, pipelines and/or hazardous
 substance facilities should be developed.  Planners can adopt the relevant items listed below and then fill
 in the adjacent blank columns with relevant information.


                         MATERIALS TRANSPORTED BY RAILROADS

 ¥3M                                              IMPACTS/REMARKS/CORRECTIVE ACTION

 A    Name  and location of  railroads  crossing
       watersheds or water supplies

 B.    Title and telephone numbers of company                                       ,,
       office to contact in event  of emergency (24-
       hour coverage)

 C.    Location of railroad on maps showing water
       utility's water supplies and tributaries

 D.    Location of railroad's nearest cleanup crew

 E.    Hazardous materials commonly transported

 F.     Nature  of hazardous materials transported
       (petroleum  or chemical   type,   toxic  or
       nontoxic, special hazards)

 G.    Protective features or equipment provided by
       railroad to protect water utility in event of
       spill

 H.    Improvements  planned by railroad or  water
      company to reduce vulnerability of utility to
      spills

 I.     Nature of additional investigations required
      to reduce vulnerability

J.     Other factors
      1 Adapted from Emergency Planning and Response - A Water Supply Guide for the Supplier of
Water. New York State Department of Health, January 1984.

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                                                                                       Page E-.
                                    Appendix E (continued)

      EXAMPLE OF HAZARDOUS MATERIAL SPILL VULNERABILITY SURVEY CHECKLIST


                        MATERIALS TRANSPORTED BY HIGHWAYS

ITEM                                              TMPACTS/REMARKS/CORRECTIVE ACTION

A.    Information  on interstate, U.S., and  major
      state highways with respect to watershed or
      source of water supply is available in files as
      follows:

      1.    Maps showing the  routing  of major
            highways within the watershed and near
            water-utility facilities

      2.    Maps showing drainage patterns from
            major  highways   with   respect  to
            watershed and water utility facilities

B.    For carriers of hazardous materials dispatched
      locally, title and telephone number of office
      to be notified in event of an accident (24-hour
      coverage)                                                     :

C.    Hazardous materials  commonly transported

D.    Nature of hazardous materials transported
      (petroleum   or   chemical  type,  toxic  or
      nontoxic, special hazards)

E.    Highway  authorities  to  contact  regarding
      elimination of local  highway conditions that
      could cause spillage accidents

                          MATERIALS TRANSPORTED BY PIPELINES

                                                   TMPACTS/REMARKS/CORRECTIVE ACTION
 ITEM

 A.


 B.



 C

 D.
Name  and  location  of  company owning
pipelines crossing watersheds or water supplies

Name  and telephone number  of company
office to contact in event of emergency (24-
hour coverage)

Materials being transported

Nature' of material  (petroleum or chemical
type, toxic, or nontoxic, special  hazards)

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 ITEM

 E.



 F.

 G.
                               Appendix E. (continued)

 EXAMPLE OF HAZARDOUS MATERIAL SPILL*?ULNERABlLITY SURVEY CHECKLIST


              MATERIALS TRANSPORTED BY PIPELINES (continued)

                                             IMPACTS/REMARKS/CORRECTIVE ACTION

 Drawings of pipeline  routing  showing line
 valving (may be plotted on base maps  for
 railroads, etc.)

 Line size and installation date

 Frequency of line testing
 H.    Determination that owner has an acceptable
       shutdown procedure
 I.

 J.


 K.
ITEM

A,


B.



C.

D.



E.
 Public agency responsible fdf line safety

 Pipeline leaks  in  last  ten  years that have
 endangered water supply

 Determination   that  pipelines   carrying
 hazardous materials  through watershed are
 cathodically protected

          FIXED-STORAGE FACILITIES FOR HAZARDOUS MATERIALS

                                          ,  IMPACTS/REMARKS/CORRECnVE ACTION

 Name and location of company handling or
 storing hazardous materials near water supply

 Name  and telephone number  of company
 office to contact in an emergency (24-hour
 coverage)

 Materials being  stored

 Nature  of materials  stored (petroleum  or
 chemical type,  toxic or  nontoxic, special
 hazards)

 For tanks storing hazardous materials installed
 underground such that a leak could pollute
the groundwater supply; determination that
tanks   are   cathodically   protected   and
periodically leak tested

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                                                                                      Page E-4
                                    Appendix E (continued)

      EXAMPLE OF HAZARDOUS MATERIAL SPILL VULNERABILITY SURVEY CHECKLIST


          FIXED-STORAGE FACILITIES FOR HAZARDOUS MATERIALS (continued)

ITEM                                             IMPACTS/REMARKS/CORRECTIVE ACTION

R    Determination whether drainage from  the
      storage  site  is  safely  conveyed .off  the
      watershed or treated before disposal

G.    Check for overflow  alarms installed  on
      hazardous materials storage tanks

H.    Check of catchment basins  for  hazardous-
      material spills for suitable containment dikes

I.    Adequate protection  by  local  ordinances
      against deficiencies in storage facilities  that
      handle hazardous materials should be verified

J.    Check of local building departments making
      periodic  inspections  of  storage  facilities
      handling hazardous materials for conformance
      to applicable regulations

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 1.
                                    Appendix F

       LIST OF SOURCES OF INFORMATION ON HAZARDOUS MATERIALS


      List of Extremely Hazardous Substances and Their Threshold Planning Quantities
      40 CFR Part 355, Appendices A and B.

      List chemicals which are "acutely lethal," with threshold quantities at which point the
      operator  or  owner of the facility must report  to the  State emergency response
      commission,  the local emergency planning committee, and the fire department with
      jurisdiction over the facility.  The list is limited to acutely toxic chemicals; it does not
      list all potential sources of contamination.

2.     Hazardous Materials Table.  49 CFR 172.101.

      Lists all materials determined to be hazardous by the Department of Transportation
      These materials may be released by incidents on highways, railroads, or navigable
      waters.                                                                  6
 3.
 4.
5.
6.
7.
     Optional Hazardous Materials Table.  49 CFR 172.102.

     Supplements Hazardous Materials Table.

     List of Hazardous Substances and Reportable Quantities, Table 302.4. 40 CFR 302.4.

     List of hazardous substances reportable under the provisions of CERCLA.

     Hazardous Constituents.  40 CFR Part 261, Appendix VIII.

     Lists hazardous constituents for which there  are reporting requirements under the
     provisions of RCRA.

     Hazardous Waste Excluded from Non-Specific Sources.  40 CFR Part 261, Appendix
     LX.

     Supplements Hazardous Constituents List.

     Hazardous Waste Excluded From Specific Sources. 40 CFR Part 261, Appendix IX.

     Supplements Hazardous Constituents List.

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                                     Appendix G

            SHORT-TERM AND LONG-TERM REPLACEMENT OPTIONS
Emergency and Short-Term Replacement Options

      Although options that are viable on an emergency or short-term basis may  differ
depending on the circumstances of the supply disruption incident, they are discussed
together here. A summary of the types of emergency and short-term options available are
shown in Exhibit G-l.  The following discussion  of replacement options is organized
according to those that are available from within the water system and those that must be
obtained from outside  of the system.

A.    Alternative  Supplies Within the System

      1)    Water System Management

                 One  option available to supply systems with several wells or more
           than one wellfield is to contain or dilute the contaminated supply while
           meeting demand from other wells or wellfields. Containment can involve
           shutting off the well or wellfield or adjusting the rate of withdrawal from
           neighboring wells.  Another option is to  continue pumping  from the
           contaminated  source  while  preventing  the water  from entering the
           treatment or distribution system.  In some cases, such as intrusion by
           saline water, it  may  be acceptable  to blend  contaminated  supplies,
           especially when the existing treatment system can adequately handle the
           contaminant in dilute concentrations.

                The viability of water system management as an emergency or
          short-term option depends on prior design  of the system and a detailed
          knowledge of the hydrogeology.  It will not be feasible for small systems
          which  rely on a single well or several wells drawing from the same area
          of a contaminated aquifer.   In addition, the source of contamination
          must be precisely located and identified and the contamination plume
          mapped.

               The benefits of this alternative are substantial. Because it requires
          no additional equipment and  relies on existing capacity, it is a low-cost
          alternative which minimizes interruptions to service.

    2)    Use of Stored Supplies

               In an  emergency situation,  stored  supplies can meet immediate
          demand if a major supply has to be shut off.  However, many systems
          have only  limited storage capacity.  This is especially true in areas with
          limited supplies of water.  In some cases,  ground-water and  riparian
          rights are tied directly to actual use of available supplies; water storage
          may be politically or legally infeasible. Another factor to consider with
          stored supplies  is the need to assure quality. Stored supplies must be
          treated and protected from contamination.

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-------
                                Appendix G (continued)

             SHORT-TERM AND LONG-TERM REPLACEMENT OPTIONS
 Emergency and Short-Term Replacement Options (continued)

      3)    Excess Capacity

                  Many wellfields  have excess capacity which can be tapped in an
            emergency or short-term situation. The analysis of water supplies should
            identity wells and wellfields with the potential for expanded yields.  The
            viability of this alternative depends on prior planning; detailed hydrologic
            information and equipment must be available.

                  Again, there may  be political  and legal problems with this
            alternative, especially in areas with limited supplies.  In addition, the cost
            of maintaining and accessing excess capacity may be prohibitive. Finally,
            reliance on excess capacity as an emergency replacement option requires
            a detailed knowledge of the hydrology of the wellfields.

                  The benefit of this alternative is that it does not require bringing
            in outside supplies.  In certain situations, it may also be cost-effective if
            there are only limited logistical requirements.

B.    Alternative Supplies Outside the System

      1)     Bottled Water

                 In an emergency situation which requires the wells or wellfields to
            be shut off, bottled water may be the best alternative supply  of drinking
            water.  Bottled water has certain advantages.  In  many cases, sufficient
            supply is immediately available either in stores or at the bottling facility.
            Using or recommending the use of bottled water  has a low  cost to the
           water purveyor.   In  most situations, the quality of the bottled water is
           assured, especially in states were bottled water is regulated and sampling
           for contamination is required on a regular basis.

                 There are disadvantages to bottled water as well.  The supply may
           not be sufficient to  meet  a sustained demand for drinking  water.  In
           addition, bottled water cannot meet the need for fire safety or industrial
           use.  There is potentially a high cost to the consumer, especially  if the
           supplier takes advantage of the situation. High cost may be a problem
           in areas where  bottled supplies are transported  over  considerable
           distances. Finally, the source of bottled water may be contaminated; in
           some states, sampling of bottled water supplies dose not cover the full
           range of potential contaminants.

     2)     Tank Trucks

                Alternative  supplies can be brought in by tank truck.  In many
           states, the National Guard maintains a supply of "water buffaloes" which
           are tank trucks intended for transporting water. -An alternative source
           of transportation may be milk trucks or tank trucks  used for  transporting
           other materials.  Careful attention must be paid to avoid bacterial

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r
                                                                                                 Page G-
                                                   Appendix G (continued)

                                SHORT-TERM AND LONG-TERM REPLACEMENT OPTIONS
                    Emergency and Short-Term Replacement Options (continued)
                                contamination and evaporation. In addition, the source of water brought
                                in by tank truck must be sampled and monitored.  If, this option is
                                selected  a source of sanitary containers should be identified so that
                                homeowners are not required to  use  their own, possibly contaminated,
                                receptacles.

                           3)    Surface Water

                                      In many cases, ground-water supplies are a preferred alternative to
                                surface  water  supplies,   principally   because  of  problems  with
                                bacteriological pollution in surface waters. If an available surface water
                                supply is treatable, it may be a viable alternative.  However, treatment
                                technology may be difficult to put in place and require a high level of
                                capital investment; surface water  is therefore not a preferred emergency
                                option, although it may be an attractive short- or long-term alternative.

                           4)   Interconnection with Another Supply System

                                      Many  communities  may link  into  the water supply system of
                                 another community.  This alternative requires considerable planning and
                                 the availability of the appropriate equipment to connect the alternative
                                 supply to the distribution system. It also requires excess capacity in the
                                 other system. Finally, it depends on the capacity, quality, and operations
                                 of the other system.   As a  result, it  may not be a viable emergency
                                 option,  although it may be the most cost effective short- and long-term
                                 option.

                      C.    Modification or Reduction  of Water Use

                            1)   Conservation

                                       In an  emergency situation which requires a complete  or partial
                                 shutoff of the wellfields  and wells, non-essential water  uses must be
                                 restricted,  preferably by voluntary conservation measures.   Users can
                                 reduce consumption  by limiting activities such as industrial  processes,
                                 landscaping, laundry, bathing, washing cars, etc. Purveyors should make
                                 an effort to educate  consumers about conservation techniques  prior to
                                  contamination incidents.   This  option is especially attractive for those
                                  cases where contamination is restricted to a portion of the water supply,
                                  since it eliminates the need to provide alternative supplies immediately.

                            2)    Modification of Use

                                        Some  forms  of   contamination,   especially  bacteriological
                                  contamination, may  require some  modification of use,  such as boiling
                                  drinking water for a prescribed period. In order for this to be a viable
                                  alternative, methods of communicating such information to homeowners
                                  should be identified  in advance. The principal benefit of this alternative

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                               Appendix G (continued)

            SHORT-TERM AND LONG-TERM REPLACEMENT OPTIONS
Emergency and Short-Term Replacement Options (continued)

           is that it does not interrupt water service.  It is only possible, however,
           when the type of contamination is precisely identified.

D.    Treatment of Water Supplies

      1)    Additional Treatment with Existing Equipment

                 In some  cases, contaminants  can be effectively  treated by  the
           existing treatment  system.  This alternative is limited by the treatment
           system capacity and usually only is viable for bacteriological and mineral
           contaminants.  In cases where there is a dramatic increase in the level
           of contamination,  careful operation of the treatment  system will be
           necessary; as a result, additional treatment is only a viable alternative if
           there is a full-time operator and monitoring system available.

     2)    Point-of-Use Treatment

                Home treatment systems may be a cost-effective means of securing
           a  safe supply of drinking water in  some circumstances. This may be the
           case when private wells are affected and no municipal interconnection is
           within close proximity.  It is not a viable alternative in an  emergency
           situation because of time and technical expertise required to  install the
           equipment. There  are three common designs:  1) faucet mount of line
           by-pass  activated carbon filters;  2) reverse  osmosis  or  ultraviolet
           combined with activated carbon; and 3) air strippers.

                The treatment methods used in these designs have been proven in
          larger scale equipment.  They have been adapted for home use with good
          results in some cases. However, there are a number of operating and
          maintenance factors which significantly affect their removal capabilities.
          Therefore, the use of such devices  should only be made after the careful
          evaluation of manufacturers' testing data, and if there is a provision for
          scheduled professional maintenance of such devices

    3)    Additional Treatment with New Equipment

               Treatment technologies  can  also be applied to  the water supply
          system.  Treatment method selection depends upon a number of factors,
          including the chemical characteristics of the contaminants,  the extent and
          severity of the contamination,  the treatment removal objective, and the
          financial and technical resources available.  The method of  treatment
          used to treat the contaminated supply depends primarily on the type of
          contaminants being removed. Treatment systems may be relatively simple
          when a single chemical is involved or extremely complex when  a number
          of  contaminants are involved.  The  basic types of treatment technologies
          for organic chemicals in ground water are air-stripping, activated carbon,
          and biological treatment.  Chemical precipitation is used for the removal
          of  inorganic chemicals.

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                                                                           Page G-6
                              Appendix G (continued)

           SHORT-TERM AND LONG-TERM REPLACEMENT OPTIONS


Emergency and Short-Term Replacement Options (continued)

                 Additional treatment with new equipment may not be a viable
           alternative in an emergency situation. The technologies can have a high
           cost and may require technical expertise.   In addition, the amount of
           time  required to put the equipment in place may be significant (1-7
           days). In general/treatment of the water supply should be viewed as a
           short-term and long-term option.
Long-Term Replacement Options

      Lone-term water replacement options differ from emergency and short-term options
in two ways.  First, the amount of time available to  evaluate the various alternatives is
longer, permitting more extensive analysis and the consideration of future needs and other
factors prior to  a decision being .made. Second, the range of alternatives which are viable
is lareer   Provided that an interim solution has been put in place, officials  can use
replacement options which require more extensive capital investment and more time to
implement.  A  summary of the long-term replacement options available is provided in
Exhibit G-2.

 A.    Provision of Alternative Supply from Within the System

       1)    Water System Management

                  This option  is viable in the long-term, although it reduces the
            ability of the water supply system to respond to increased demand in the
            future. Combined with a strategy of aquifer remediation, it may be an
            effective option.

       2)     Stored Supplies

                   This is not a viable alternative.  Storage capacity in most supply
             systems does not exceed several weeks consumption.

       3)    Excess Capacity

                   While the use of excess capacity alone will reduce the opportunities
             of the community to expand in the future, it may be  one of the most
             cost-effective alternatives since it requires almost no capital investment.

  B.   Provision of Alternative Supplies from Outside the System

       1)    Bottled Water

                   This is  a viable alternative  in  some  circumstances, but  not
             recommended.  It fails to  satisfy the demand  for  water uses besides
             drinking water.  In addition, consumers have to bear the burden of higher
             costs for water over an extended period, which may encourage  them to
             resume using contaminated water supplies.

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                                                                              Page G-9
                                Appendix G (continued)

             SHORT-TERM AND LONG-TERM REPLACEMENT OPTIONS
 Long-Term Replacement Options (continued)

       2)    Tank Trucks

                  Again, this is a viable alternative but is not recommended.  As in
            the case of bottled water, it may be difficult to meet the demand  for
            water uses besides drinking water.  The costs of maintaining a fleet of
            tank trucks would be substantial.

       3)    Surface Water

                  This may be a good alternative if supply and adequate treatment
            technology is available.  A major factor, especially in areas with limited
            water supplies, is riparian rights.

       4)    Interconnection with Another Water Supply System

                  Despite the capital investment required to link with a neighboring
            public water supply, this may be a cost-effective solution.  In addition,
            it reduces the difficulty involved in locating new supplies, drilling wells,
            and providing adequate treatment focilities.  A factor that has  to  be
            resolved is the loss of autonomy by the community; a direct consequence
            is the possibility of higher water rates.

      5)    Drilling New Wells

                 If there is  an untapped supply of ground water in the form of a
            separated  aquifer or a portion  of the contaminated aquifer which is
            upgradient  and uncontaminated, it may be feasible to drill new  wells.
            The relative cost of this alternative depends on the hydrogeology of the
            site.

      6)    Desalinization

                 In a number of areas,  desalinization of water or saline ground
           water  may  be a  viable  alternative.   Desalinization technologies are
           available and the supply  of saline water is  relatively unlimited.

C.    Modification or Reduction of Water Use

      1)   Conservation

                 While  it is possible to use conservation strategies to reduce
           consumption over the long-term, it may not  be politically viable.
           Conservation  is  difficult  to  enforce  since  it depends on voluntary
           compliance. This is especially true if there is a substantial industrial or
           commercial demand or if  there is  projected growth in the residential
           sector.  Conservation may also have a negative effect on the financial
           condition of the water  supply system if the loss of revenue becomes

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                                                                          Page G-10
                              Appendix G (continued)

            SHORT-TERM AND LONG-TERM REPLACEMENT OPTIONS
Long-Term Replacement Options (continued)

           permanent. However, water conservation should probably be encouraged
           as part of any long-term replacement strategy.

      2)   Reduction of Water Pressure

                 Not a viable alternative because of potential damage to equipment
           and decreased fire safely.

      3)   Modification of Use

                 Not an acceptable alternative although it  may be necessary for
           extended period of time.

      4)   Dual Systems

                 By  separating potable water  from  non-potable  water in  the
            distribution system,  it may be possible to reduce the demand for drinking
            quality water while using the contaminated supply for  industrial and
            commercial purposes. Development of dual systems may be prohibitively
            expensive.  Buildings  and  distribution systems would have  to be
            retrofitted.   Even  if  carefully  planned,  dual  systems will require
            investment in additional materials.

 D.    Treatment of Water Supply

            The same treatment technologies previously described are  available as
       permanent  solutions  for contaminant removal.   In  this case, treatment
       technologies would be permanently installed at the treatment facility rather
       than relying on a mobile treatment unit.   Adequate  treatment of existing
       supplies is  in many cases preferable since it reduces  the demand on other
       supplies.

 E.    Aquifer Remediation

             Cleansing a contaminated aquifer involves various methods of pumping
       ground water,  treating it, and recharging the aquifer with uncontaminated
       water.   Most  aquifer remediation projects have taken place pursuant to
       Superrund  activities  under  the  Comprehensive Environmental Response,
       Compensation and Liability  Act  (CERCLA).   This option will only be
       considered if water supply treatment is not viable or there are no alternative
       sources of long-term supply.

             The  disadvantages of  aquifer restoration are  considerable.  Aquifer
       restoration is time consuming and costly and the results are uncertain.   In
       addition, the experience has  been that the public may not accept a drinking
       water supply produced from  a restored aquifer.

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                                                                              Page ff-1
                                     Appendix H

                          POTENTIAL FUNDING SOURCES
 State Funding Sources

      Most States operate their own funds or fee systems, similar to the Federal Superfund,
 for emergency response and cleanup of hazardous waste contamination.  Some States simply
 provide funds to finance the State share of Federal Superfund cleanups; others finance the
 cleanup  of sites that are not priorities  for Federal Superfund  aid.  The 1986  Superfund
 amendments clarified that the federal law does not preempt State statutes.

      State funding mechanisms vary, usually including a combination of "front-end" taxes
 of industries; "back-end" taxes on waste generation; general fund appropriations; recoveries
 from liable parties; and penalties and fines.  One of the oldest State clean-up  statutes  is
 the New Jersey Spill Compensation and Control Act, enacted in 1976.  This act created a
 revolving fund to be used to cover "all clean-up and removal costs and for  all  direct and
 indirect damages," including the costs of restoring or replacing ground water.  Parties with
 any responsibility for hazardous substances  removed by the fund  are strictly liable for all
 clean-up and removal  costs.

      Connecticut's water pollution control law addresses water replacement needs directly.
 In the  event of water  supply contamination,  the State is  authorized to issue orders
 requiring responsible parties or the affected municipality to provide alternative drinking
 water supplies.  The law also requires the State to  use its emergency spill response fund
 to finance short-term drinking water supplies until responsible parties do so.  Connecticut
 also provides grants to municipalities for  water supply replacement  for the  first year.
 Other States,  such as Massachusetts,  also have created funds earmarked for water supply
 cleanup and replacement.   Many States are also establishing  underground storage tank
 funds, compatible with the federal program, and oil spill clean-up funds.

      Funds for construction or rehabilitation of water supplies may also be available from
 other traditional State grant programs, such as public facility construction grants, low-
 incoming housing, and community or urban development programs.

      In some instances the facility or the party responsible for the contamination can be
 held liable for the costs of cleaning up the contamination, including emergency responses,
 studies, provision of alternative water supply, and the actual cleanup itself.  Congress and
 State legislatures have created new liability mechanisms in recent years, both to finance
 cleanups and to create economic disincentives to pollute.

      Some States' statutes  expand the concept of responsible party liability beyond that
of federal statutes.  States  such as Maine, New Hampshire, Rhode  Island, and North
Carolina permit private parties to recover for clean-up costs and/or damages.  Other states,
including  California, Florida, and South Carolina, authorize private claims directly against
the state Superfund. A few States, including New Jersey and Massachusetts,  allow for the
recovery of punitive damages. Another approach is to require responsible parties to clean
up contamination as a condition of State ground-water discharge permits.  New Jersey and
Connecticut are among the  States with this  authority.

      Beyond the specific liability provisions of these statutes, a community might consider
suing potentially responsible parties  to  recover costs  and  damages using tort or other
liability theories,  such  as  public  nuisance,  negligence,  trespass,  or strict  liability.
Communities should realize, however,  that few toxic tort cases concerning ground-water

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                                                                           Page H-2
                              Appendix H (continued)

                         POTENTIAL FUNDING SOURCES
State Funding Sources (continued)

contamination  have been  decided,  and  it can  be  difficult  to prove the source  of
contamination, the damage or injury caused by exposure to the contamination,  and the
appropriate remedy in a court of law.
Federal Superfund Program

      The  U.S. Environmental  Protection  Agency manages  several funding programs
relevant to replacement of contaminated ground-water supplies. The most significant is the
Superfund Program, created by the Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA) of 1980 and expanded by the Superfund Amendments and
Reauthorization Act of 1986.  The Superfund program provides for emergency response
and cleanup of hazardous  substances which threaten public health or welfare or the
environment.  High priority is given to releases that contaminate drinking water supplies.

      Under Superfund, hazardous substances are defined as any substances listed as toxic
or hazardous under any federal pollution control statute, excluding oil and petroleum
products.  EPA uses Superfund  primarily to address problems caused by abandoned sites.
EPA administers  the  Superfund program directly, with only a limited  role  for States,
localities, or private parties.                       .                  .

      EPA can take two types of actions under Superfund; "removal actions" and "remedial
actions."  "Removal actions" are short-term  and limited, intended to prevent or minimize
an imminent threat.  Superfund will finance removal actions up to $2 million over one
year. "Remedial actions" are long-term or permanent responses. Any instance of a release
threatening the public health or welfare is  eligible for a removal action.  On the  other
hand, only sites placed  in  the  National  Priority List are eligible  for remedial actions.
Remedial  action can only be authorized after a lengthy analysis of options.  Both removal
actions and remedial  actions may include  the  provision of  an alternative water supply
including both drinking water and household water, if needed.

      EPA draws  from a revolving trust fund to finance Superfund actions. The Agency
 is responsible  for  securing reimbursement to the fund from those who may be  responsible
 for the contamination, defined  by the  statute  as "potentially responsible parties."  Such
 parties may include current or past owners or operators of facilities  that handle hazardous
 substances.  A State or locality may also recover damages  from the party responsible for
 the contamination. If States or  localities undertake removal action on their own,  they may
 be  reimbursed from the fund,  with some  restrictions. Reimbursable costs include  site
 assessment, training, enforcement, construction, and community relations.

       One condition of Superfund aid is that States finance at least  10 percent of the total
 cleanup costs and 100 percent of long-term operation and maintenance costs. If the source
 of contamination is a facility owned or operated by a State or political subdivision of a
 State,  then the State or municipality must cover 50 percent of  cleanup costs.  The law
 classifies the cost of restoring ground-water quality for the first ten years as a clean-up cost,
 rather than an operation or maintenance cost.

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                                                                             Page H-3
                               Appendix H (continued)

                          POTENTIAL FUNDING SOURCES
 Federal Superfund Program (continued)

      Under 1986 amendments ;to the Superfund program, localities may also be reimbursed
 for up to $25,000 per incident for temporary emergency measures.  To be eligible, localities
 must not use this funding to supplant  local emergency funds normally provided and must
 exhaust all other sources  of reimbursement first.   Localities with  the most  significant
 financial burdens receive priority for emergency reimbursement funds.
 Underground Storage Tank Program

      The  Hazardous  and  Solid Waste  Amendments  of  1986  created  a  Leaking
 Underground Storage  Tank  Trust  Fund to provide funding  for  cleanup of leaking
 underground storage tank leaks, including the provision of alternative water supply. The
 Fund has $500 million budgeted over a five-year period and is financed through a 0.1 cent-
 per-gallon tax on motor fuels.  States are required to cover 10 percent of the cost.  Priority
 for Trust Fund monies is given to cases in which prompt action is needed to protect public
 health or the environment and/or the owner or operator cannot  be identified.

 Farmers Home Administration

      The Fanners Home Administration provides grants and loans to rural municipalities
 to construct or rehabilitate public water systems.   Communities must have a population of
 less lhan 10,000 and be unable to obtain credit from private sources.  Priority is given to
 communities with lower income levels and greater  public health or safety concerns. Grants
 are also awarded to  reduce unreasonably high user charges.  Loans are made at different
 interest rates, depending on the  community's income levels.  Most  assistance takes  the
 form of a grant-loan combination.  Farmers  Home has over 300 district offices which
 process applications  for this aid.

 Corps of Engineers

      Following  a contamination incident, the Corps  of Engineers, pursuant to 33 U.S.C.
 701n, may provide temporary emergency supplies of clean drinking water.  Such assistance
 is at the discretion of the  Corps,  and  is supplemental to  community efforts. It is only
 available where the contamination poses a substantial threat to public health and welfare,
 and does not cover plan development, decontamination, or system repair. The regulations
 authorize the expenditure of up to $50,000 per incident at the  district level without prior
 approval, and authorization must  be obtained before additional  expenditures are made.
 Repayment is not required. Since this funding is meant to be supplemental to community
 efforts,  it is not recommended that it  be relied upon  as a contingency plan element,
 although local officials  should be aware  of its  availability  in the  event the system  is
 temporarily overwhelmed by a contamination incident.

 Federal Emergency Management Agency

      States can request funding  for up to 50%  of costs associated  with necessary and
essential civil defense expenses (planning and implementation) under the State and Local
Emergency Management Assistance Program.  See 50 U.S.C.  App. 2251.

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                                                                          Page H-4
                             Appendix H (continued)

                        POTENTIAL FUNDING SOURCES
Housing and Urban Development

     Community Development Block Grants are available to State and local governments
for planning and implementation activities concerning the provision of public services,
including water supply system services.  See 42 U.S.C.  5301 et seq.

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                                                                                        Page 1-1
                                          Appendix I

                    EXAMPLE OF EMERGENCY NOTIFICATION REPORT*7
      This notification report represents a typical form that might be adapted for use in a water supply
contingency plan.
PART 1 - FACTS RELATED TO EMERGENCY

1.     Person or department calling in emergency _

      Phone No./Radio frequency	

2.     Location of emergency
Date/Time call received
      Street and Home/Building number
      Other (approximate location, distance from landmark, etc.)
3.    Nature of the emergency (e.g., broken water main, chemical spill, lost pressure in home, etc.)
4.    Condition at scene
5.    Actual/Potential damage (briefly describe the situation)
6.    Access restrictions, if any
7.    Assistance already on the scene (who, what are they doing, etc.)
 PART 2 - EMERGENCY INVESTIGATION

 1.    Personnel investigating emergency	
 2.     Reported results of investigation
 3.     Time Assessed
       1 Adapted from Emergency Planning and Response - A Water Supply Guide for the Supplier of
 Water, New York State Department of Health, January 1984.

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                                                                                           Page 1-2
                                      Appendix I (continued)

                      EXAMPLE OF EMERGENCY NOTIFICATION REPORT*
PART 3 - EMERGENCY ACTION TAKEN
1.    Immediate action taken	
      Is immediate action:  Permanent
                        Temporary
3.    Was an emergency crew dispatched:  Yes	  No	     Time arrived on scene
4.    Note all other actions that will be necessary to bring the water supply system back into operation:
PART 4 - PERSONS/DEPARTMENTS NOTIFIED OF EMERGENCY
            Positions
   Chief Operator
   General Manager
   Local Health Department
   Engineer
   Operations Supervisor
   Plant Manager
   Shift Operator
   Fire Department
   Police Department
   Highway Department
   Local Elected Official
   (Mayor, Commissioner, etc.)
   Department of Health
   Department of Transportation
   Department of Environmental
   Conservation
   County Civil Defense
   Other (refer to system personnel
   and support call-up lists)
   Priority water users
   News Media
Name
Work Phone    Home Phone     Time of Call
                                                       Signature of Person Who Filled Out Form
*  To be completed and used by water supply system personnel.

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                                                                             Page J-l
                                     Appendix J

                                PUBLIC EDUCATION
      In general, the public is unaware of basic ground-water concepts, and this lack of
knowledge often frustrates communication efforts  when a contamination incident occurs.
The public should be educated about its water supply system so that basic information is
lodged in the public consciousness before any contamination incident occurs. The following
fundamentals should be covered in any public education program:

           What ground water is;
           How ground water is distributed;
           How ground water can become contaminated;
           Measures taken to ensure that the water supply is safe; and
           The basis for the water rate structure.

      There are  a number of ways to educate the public concerning its ground-water
supply.   Some are more costly than  others and  some depend upon  the extent of the
community's communication resources. Listed below are a number of potential  methods
for reaching the public:

      A   Pamphlet to customers — This could be a separate mailing to customers,
           or could be included with their rate notice.

      B.   Newsletters to customers - Utilities often send brief newsletters to their
           customers along with their rate notices with different aspects of the water
           supply system featured. The frequency of distribution can vary, depending
           upon the system's resources, from monthly to even yearly.

      C.   Newspaper articles — Newspaper articles are an inexpensive and efficient
           way to communicate the basic elements of the water supply system.  In
           larger communities, system staff should approach the science editors  of
           local and regional papers. The contact may be less  formal in smaller
           communities,  where local  and regional papers may rely upon general
           reporters and donated features.

      D.   Television and radio — Television and radio can also be used to educate
           the public in an inexpensive  and efficient way.   Contacts made with
           television and radio personnel may also  be useful during a contamination
           incident.  If  funding  permits, public service announcements could be
           prepared.

      E.   Presentations to civic groups - Civic groups in residential neighborhoods
           generally welcome'presentations by utility personnel and the groups are
           an excellent means of establishing contact with local civic leaders, whose
           support may be valuable following a contamination incident.

      F.    School programs — Early education can provide a lifetime awareness of
           the value of  a safe drinking water supply.   An effort can be made to
           include ground water and the water supply system as topics  on local
           school civics or science curricula.

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                                                                            Page J-2
                              Appendix J (continued)

                               PUBLIC EDUCATION
      After contamination  of a  public water supply well has been detected, the initial
public communication is crucial  to  maintaining public confidence in the integrity of the
water supply system.  The duration of the initial communication phase may vary depending
upon the severity of the contamination incident, but it encompasses  the time from the
discovery of the contamination to the  provision of interim remedial measures. While the
precise information that needs to be  transmitted also will depend upon the nature and
extent of the  contamination, the  water replacement contingency plan can contain a list of
the types  of information most likely to be important  to an interested public.  This list
should include the following:

      A.    Federal and State Notification  Requirements  — Pursuant  to Section
           1414(c) of the  Safe  Drinking Water Act (42 U.S.C. 300g-3(c))  public
           water system owners or operators must  notify their customers of any
           failure to comply with a maximum contaminant level (MCL)  established
           in a national primary drinking water regulation (NPDWR), failure to
           comply with a prescribed treatment technique established  in lieu of an
           MCL, failure to meet a variance or exemption schedule, failure to comply
           with monitoring requirements or a testing procedure prescribed by an
           NPDWR, and operation pursuant to  a variance or exemption.  Current
           regulations governing the manner and form of the public notification are
           found at 40 CFR 141.32.   In addition, States are free to  adopt  public
           notification  requirements that are  more stringent  than the  federal
           requirements, and any  applicable State  requirements should also  be
           referenced in the contingency plan.

      B.    Water Supply System Information  -  Basic information on the location
           of wellfields and the distribution system.

      C.    Identify the Contaminant — The name of the contaminant, what it is used
           for, any chemical or physical properties that  are easily explained (such
           as the ability to degrade), toxicity information, and the concentration that
           has been detected.

      D.    Water Use  Restrictions —  Impermissible  and permissible water uses
           should be given. Whether the public can drink the water is obviously the
           most important information to convey at this stage. However,  people will
           also want to know whether they can use it for bathing, washing dishes,
           or watering the lawn.

      E.    Boil Orders  —  In cases of bacterial  contamination, the public may be
           directed to boil water for  drinking uses.

      F.    Conservation — In situations  where  the  ability to supply customers is
           jeopardized, the public may have to employ water conservation measures
           to ease the  demand.

      G.    Impact on Water Supply — The impact on the availability of water can
           be illustrated with a description of the hydrogeologic area and the supply
           components affected by the contaminant.

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                                                                              Page J-3
                               Appendix J (continued)

                               PUBLIC EDUCATION
      H.   Alternative Supplies --  A list of the source(s) of alternative water
           supplies should be provided, including information on how this water will
           be made available to the public.

      I.    Risk Assessment -- This is very difficult information to convey without
           creating frustration and confusion.  Avoid comparisons to other types of
           risks, e.g., driving a car versus drinking the contaminated water.  In some
           instances, particularly with relatively low-level contamination and short
           public exposure, it will be impossible to quantify the risk in a meaningful
           way.  Give figures where available, stress the margin of safety built into
           drinking water standards, discuss the steps taken to eliminate  any  risk,
           and do not trivalize the significance of the contamination.

      J.    Actions Taken and Planned —  Detail the steps the water supply system
           has taken and will take to address the incident.

      K.   Duration of the Incident — Be realistic in addressing  the long-term
           impact of the incident. There is a temptation to be optimistic in making
           predictions on the resolution of the incident, but it is important for the
           sake of credibility to avoid building up unrealistic public expectations.

      L.   Future Public  Communication  --  Set  forth  plans  for continued
           dissemination of information to the public.

      M.   Contamination Source ~ To avoid liability for false statements, do not
           make  any  accusations  that  cannot  be  substantiated.    Where  the
           contamination source is verified, provide a straightforward account of the
           facts; avoid speculation.

      Methods  of  communicating the  above information  to the  public  regarding a
contamination incident include:

      A.   Select a Spokesperson ~ To ensure consistency and accuracy, one person
           should be responsible for the flow of information to the public and the
           media.  The  plan  should designate this  spokesperson, with alternates
           indicated.  The type of person  chosen may depend upon the size of the
           water system - a large system may have a public relations officer, while
           a very small system may have only a couple of employees from  which to
           choose. For credibility's sake,  the spokesperson  should be local, either
           an employee of the water system or a municipal official. State personnel
           can be available  for  referral on some questions,  but should not be the
           primary information source as the public will lose confidence  in the
           water  system  if it is  perceived  that outside entities  are taking  over the
           remedial action.   The spokesperson must be knowledgeable about the
           supply system and must be in close contact with those responding directly
           to the contamination incident.

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r
                                                                                                   Page J-4
                                                     Appendix J (continued)

                                                     PUBLIC EDUCATION
                           B.    Have Information Sheets Available - Some of the information that needs
                                 to be disseminated during the  initial communication  phase can  be
                                 prepared in advance, such as water system information, boil orders, and
                                 conservation measures.  It may be appropriate to have a prepared "initial
                                 news release," similar  to  that  shown in  Exhibit J-l, that notifies the
                                 public that  there has been  a contamination incident, and  gives system
                                 personnel some time to assess the incident and prepare a more detailed
                                 "explanatory news release."

                           C.    Contact Media - The contingency plan should list by name, organization,
                                 and  phone number-the radio, television, and newspaper personnel to be
                                 contacted  by the  spokesperson.    A  press  conference  may be  an
                                 appropriate venue for disseminating information to the media, depending
                                 upon the size of the community and the  seriousness of the incident.

                           D.    Contact External Notification Network - The contingency plan should
                                 contain a list of local,  regional,  State, and federal personnel who are
                                 likely to be contacted by the media following a contamination incident,
                                 e.g.  local politicians, congressmen, civic  leaders, the governor.  These
                                 individuals  should be provided with the basic facts  surrounding the
                                 incident,  and can be requested to  refer the media to  the designated
                                 spokesperson.

                           E.    Notify Public Directly -  If  there is  an acute  public health  threat
                                 associated with the contamination incident,  it may  be  necessary to
                                 disseminate information directly through dramatic methods, such as civil
                                 defense  sirens,  sound trucks, and door-to-door notification.   The
                                 contingency plan  should list  civil  defense contacts and  their  phone
                                 numbers.

                            It  is important to keep the  public  informed following the initial  communication
                      phase.   Interest in  the problem  may  wane  if providing alternate supplies  has  caused
                      relatively little public inconvenience and support for costly, long-term solutions may erode.
                      If the  public is  experiencing long-term inconvenience as a result of the incident, it will
                      want periodic reassurance that efforts are underway to restore the  water  supply system.
                      The following are progress  report  items which should be referenced  in the contingency
                      plan:

                            A.   Federal and State Notification Requirements - The initial communication
                                 requirements listed above include provisions for notification in the event
                                 of ongoing violations.

                            B.   Status of Use Restrictions  — As  more information on  the nature and
                                 extent of the contamination becomes known, the  water  use restrictions
                                 and conservation measures  may change.

                            C.   Time Frame for Permanent  Remedial  Measures  - Avoid  excessive
                                 optimism so that public expectations remain realistic.

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                                                                                              Page J-5
                                             Exhibit J-l

                                 SAMPLE INITIAL NEWS RELEASE
                               (For distribution to previously identified
                             television, radio, and newspaper personnel.)
The following substance has been detected in the
                                      system:
It is vital that all residents in the	
use restrictions until further notice:
               area observe the following water
The characteristics and potential public health hazards associated with this contaminant are as follows:
City and water system personnel are taking the following steps to address the problem:
For further information please contact	
number: 	.  A press conference is scheduled for
                                 at this phone
to be held at	
as additional information becomes available.
             _.  News updates will be provided
Attached please find a copy of an information sheet which provides details concerning the physical plans,
organization structure, and function of the	water system.
Time: im

Signed:

Title:
Date:

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                              Appendix J (continued)

                               PUBLIC EDUCATION
                                                                                       Page 3-6
      D.   Options Under Consideration - Describe permanent supply replacement,
           treatment, and cleanup options. Public comment may be solicited.

      E.   Cost and Funding -- Detail response costs to-date and give estimates of
           both future costs and possible sources of funding.

      F.   Investigation Results — Name the source of contamination 'if it has been
           confirmed  by  investigation.    Avoid  finger-pointing  without  clear
           substantiation.

      The urgency of the situation is  likely to  have  lessened by the time the progress
report phase has been reached and time can be spent in building upon the good relations
established during the initial communication phase. The following are recommendations
for maintaining positive public relations:

      A.   Prepare a regular progress report on the situation;

      B.   Continue to direct  all communication through the designated local
           spokesperson;

      C.   Refer difficult inquiries to technical  personnel (State or local); and

      D.   Hold regular press conferences if the severity of the situation warrants.

      Once permanent remedial measures have been selected, it is important to notify the
public in a manner that fosters support for the water supply system's decision.   The
following should be included in this notification:

      A.   Memory Refresher - In  some situations, the  public may need to be
           reminded as to why there is a problem that needs correcting.

      B.   Details of Long-Term Option Selected - Include as much information
           on the option selected as the public can easily digest.  Explain why it will
           provide  a safe,  permanent solution,  and  why  it  was selected  over
           alternatives.

      C    Costs — Give an accurate assessment of the costs involved.

      D.    Funding Strategies - Detail how the water supply system intends to pay
            for the option it has selected.

      Because the selection of a long-term solution may have financial  implications for the
water supply system's customers,  the method of  communication should be straightforward
and allow for no hint of  impropriety on the part  of  system personnel.   Advance
information "leaks" should be guarded against.   The following should be considered  as
means of notifying the public about the costs of long-term options:

      A.    Notice Directly to Customers — By special mailing, or included with rate
            notices.

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                                                                                 PageJ-7
                        Appendix J (continued)

                         PUBLIC EDUCATION
B.    Statutory Requirements - In some States, there  may be  notification
      requirements  if  rate  increases  or other  funding  mechanisms  are
      contemplated.

C.    Press Notification — By progress report or press conference.

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                                                                                          Page K-l
                                           Appendix K

                       CLASSIFICATION OF WATER USES AND OPTIONS
             FOR DEALING WITH SHORTAGES AND WATER QUALITY PROBLEMS7
      Public water suppliers should develop a classification  system of water uses to reflect water use
priorities.  A classification system clarifies issues  of fairness,  hardship  and,  ultimately, management
effectiveness.  Four classes of water use are recommended:  First, Second, and Third Class Essential Uses
and Non-Essential Uses.  Essential uses might include water for domestic use, health care facilities, other
public institutions, emergency shelters, and firefighting. Non-essential uses might include water used for
ornamental purposes, outdoor non-commercial watering, etc.  Even though a  system might choose to use
a standby pricing structure or other measures  to curb water use demand,  classifying and analyzing uses
according to their contribution to the system's overall demand may reveal a plan weakness or need for a
back-up strategy.  In managing water during a drought, plans that primarily rely on non-restrictive options
(i.e., pricing, pressure reduction, etc.) could also superimpose a scheme of restrictions where necessary to
establish a balance between water use  and supply.  "Recommended  Water  Use  Classes  and  Class
Restrictions," illustrated below, shows an approach for managing water under deteriorating supply conditions.
Under more quickly developing water shortage situations, such as those caused by a chemical spill, power
outage,  etc., the options listed under "emergency" conditions, as appropriate, should be incorporated into
the development of the system's emergency operations procedures.
                      Recommended Water Use Classes and Class Restrictions
                                     (Wood and others, 1986)
                                                      Program Phase
    General Water Use Class

    Essential, First Class


    Essential, Second Class


    Essential, Third Class

    Non-Essential
   Conservation
Voluntary Cutbacks
Voluntary Cutbacks
Voluntary Cutbacks

Mandatory Cutbacks
or Bans
    Restrictions
    Emergency
Voluntary Cutbacks  Mandatory or
                    Voluntary Cutbacks

Mandatory or        Mandatory Bans
Voluntary Cutbacks
Mandatory Bans

Mandatory Bans
Mandatory Bans

Mandatory Bans
       1 Adapted from Local Drought Management Planning Guide for Public Water Suppliers. Tennessee
Department of Health and Environment, May 1988.

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                                                                                   Page K-2
                             Appendix K (continued)

               CLASSIFICATION OF WATER USES AND OPTIONS
      FOR DEALING WITH SHORTAGES AND WATER QUALITY PROBLEMS
Options for Dealing with Shortages

Water management options which a supplier should consider are listed below under the
management phase thought to be most appropriate:

I.    "Normal" Conditions

     A.   Water Conservation
           1.    Water Conservation Education
           2.    Water Saving Devices
           3.    Repair of Household Leaks
           4.    Pricing
           5.    Universal Metering
     B.   Pressure Adjustment
     C.   Leak Detection
     D-   Reservoir Evaporation Suppression
     E.   Water Saving Plumbing Codes
     F.   Reuse

II.   Under "Conservation" Conditions

     A.   Water Conservation (most of the measures applicable under "normal" conditions
           .are effective  in reducing water use under  "Conservation"  conditions)  and
           Mandatory  Cutbacks or Bans on Non-essential uses.
     B.   Media Attention

III.  Under "Restriction" Conditions

     A.   Water Conservation (Voluntary Cutbacks of First and Second Class Essential
           Water  Uses)  and  Mandatory Cutbacks or  Bans of Non-Essential and Third
           Class Essential Water Uses.
     B.   Rationing
     C.   Service Interruptions
     D.   Mutual Aid Agreements (Interconnections  with nearby systems)
     E.   Temporary  Pipelines and Sources
     F.   Additional  Wells and Reactivation of Abandoned Wells
     G.   Temporary  Impoundments
     H.   Water Recycling
     I.    Modification of Reservoir Management
     J.    Dredging to Improve Intake Capability

IV.  Under "Emergency" Conditions

     A   Restrictive  Responses (Many  of  the  Responses Appropriate  under the
           "Restrictions" phase also apply under "Emergency" Conditions)
     B.   Hauling Water
     C.   Bottled Water
     D.   Sanitation Measures

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                                                                            Page L-l
                                    Appendix L

                       SUPPORT FUNCTIONS  EVALUATION
      State planners should seek the answers to specific questions when undertaking an
evaluation of State capacity to provide support in specific categories of response activities.

1)    Problem Identification

      a)    What is the status of the State's ground-water quality monitoring efforts?

           •     Does your State health department perform drinking water quality
                 monitoring  in fulfillment of Federal requirements?

           •     If the State conducts additional monitoring, which compounds are
                 tested for?  Does this include those contaminants most likely to
                 pose a health threat?

           •     How frequently are wells monitored?

           •     Do current monitoring  procedures allow for the  pinpointing of
                 contaminated wells?

      b)    Does the State have sufficient laboratory capacity and quality assurance?

           •     Within the  State, how many State-owned, private, and university
                 labs are capable of analyzing water samples with quality assurance?

           •     What is the total volume of sampling  labs can handle?

           •     How much  does water sample analysis and verification of results
                 cost?

           •     Is there a substantial variation in testing charges among labs?

           •     Are lab results of consistent quality? Are all results automatically
                 double-checked?

2)    Public communication and education procedures

           •     Are the  lines  of authority and proper  communication channels
                 between State, county, and municipal officials well-defined?

           •     How will information regarding water supply contamination and
                 response be communicated to the public?

           •     Who will the State designate  as official spokesperson?

           •     Can public education  programs  or information campaigns  be
                 instituted to provide the public with  general information about
                 water replacement planning?

           •     Can education programs or public hearings be held to educate the
                 public about replacement options during a contamination incident?

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                                                                             Page L-2
                               Appendix L (continued)

                       SUPPORT FUNCTIONS EVALUATION
3)    Provision of technical expertise
            •    Does the State have technical expertise and information to assist
                 localities  in evaluating their replacement options and  putting a
                 remedy in place?

            •    Does the State have a system of contaminant action levels, linking
                 specified levels of contamination  to appropriate actions?

            •    Does or can the State advise system planners on technical options
                 for water treatment and replacement?

            •    What role will the State play in assisting local implementation of
                 the contingency plan in response to a contamination incident?

4)    Information Assistance

            •    Does the State provide localities with health  advisories or other
                 information on the health affects of various contaminants?

            «    Is any type of  incident  response training provided  to  utility
                 managers or local officials by the State?

            •    Does the State provide local wellhead data?

5)    Logistical Support

            •    Is the State able to provide  local logistical support to affected
                 communities?

            •    Will the State provide or help secure water distribution equipment?

            •    Is back-up manpower or emergency response personnel  available?

            •    What  are the emergency transportation  arrangements?  Have
                 provisions been made  to bring key State personnel to the site of
                 a chemical accident or other emergency?

6)    Financial Assistance

            •    What  State  funds are  available for  plan  development  and
                 implementation at the State and  local levels?

            •    Are State funds available for statewide contingency planning tasks?

            «    What approximate costs are associated with incident response?

            e    Are there sufficient State funds for estimated planning  needs?

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                                                                            PageL-3
                              Appendix L (continued)

                       SUPPORT FUNCTIONS EVALUATION
6)    Financial Assistance (continued)
                 Are State funds available to assist local water system in the event
                 of contamination?  Under what circumstances?   Will the State
                 cover initial water replacement costs or operating expenses?

                 Will the State lend local water systems  the use of consultants,
                 equipment, manpower, materials, and chemicals or help cover the
                 costs of contracting for consultants and equipment?
7)    Legal Authority
           •     What types of legal authorities does the State have to enhance
                 response preparedness at the State and local levels?

           •     Does the gtate have a,ny legal mechanisms in place that encourage
                 contamination response at the local level?

           •     Can  such mechanisms be instituted?

           •     What legal authorities are in  place at the State  level  to secure
                 compensation from parties responsible for polluting ground water
                 or otherwise contaminating drinking water supplies?

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                                                                            Page M-l
                                    Appendix M

                             ACTION LEVEL SYSTEM
      Factors to consider in developing an Action-Level System.

Action-Level 1: Emergency situation requiring immediate action.

Type of Incident Requiring Level 1 Response:

      •    Occurrence of an incident which has resulted or  may result in
           water supply contamination in the near future.

      •    Occurrence of such an incident involving toxic contaminants with
           potential carcinogenic, mutagenic, or other serious  health effects.

      •    Detection  of  contamination  at  the  supply system at a  level
           regarded as a potential health threat.

Types of Responses that may be appropriate (depending on the specific circumstances) are:

      •    Immediate containment and removal of potential contamination
           source.

      •    Identification  of   contamination   source  in   cases   where
           contamination is detected in water supply.

      •    Provision of alternative water supply  (see emergency and short-
           term replacement options in Appendix G and accompanying text).

      •    Monitoring of various points in the supply system and other media,
           if appropriate, to detect any change in contaminant situation.

      •    Public notification of situation and steps taken to  protect public
           health and water supply.

      •    Corrective action to eliminate or contain  identified source of
           contamination and contaminated soil and water.

Action Level II: Situation which allows more time for response because  threat to health
or environment is not immediate.

Type of Incident Requiring Level II Response:

      •    A source of contamination has been identified which has not yet
           reached well but eventually will do so.

      •    Contamination has been detected at the well at trace levels.

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                                                                            Page M-2
                              Appendix M (continued)

                             ACTION LEVEL SYSTEM
Types of Response:

      •    Develop model to estimate time of travel to well.

      •    Identify source of contamination.

      •    Monitor water supply with  increased frequency  to  detect  any
           change in contamination situation.

      •    Evaluate the need for alternative supply.

      •    Notify the public of situation and steps taken as appropriate.

Action  Level  ffl:    Situation  which  requires  observation  to  assess  potential  for
contamination.

Type of Incident  Requiring Level  III Response:   Potential  source  of contamination
identified which may or may  not reach water supply.

Factors Influencing Response:

      •    The proximity of the source to the well or wellfield.

      •    The type  and concentration of potential contaminants associated
           with the source.

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                                                                                         PageN-1
                                           Appendix N

                              SPECIFIC RESPONSE PROCEDURES*
                    Chemicals Accidentally Introduced Into Public Water Supplies
POLICY

      No chemicals shall be (1) applied to  treat drinking waters  or  (2) utilized in the construction of
pipes or appurtenances which come in contact with drinking water, unless specifically permitted by the
State Commissioner of Health, and approved by or meeting the standards and requirements of the Public
Health  Service, the American Water Works Association,  National Sanitation Foundation or  similarly
recognized agency as determined by the State Commissioner of Health.

      In the event that a toxic chemical has been or may be accidentally introduced into the public water
supply,  immediate action must be  taken by  the Water Supply Official, the appropriate Field Response
Personnel, and the Bureau of Public Water Supply (BPWS) to eliminate the hazardous potential.

INFORMATION

      The State Health Department, United States Public Health Service, Local Poison Control Centers,
and chemical manufacturers provide information services whereby advice may be obtained concerning the
degree of lexicological hazard of the chemical agent involved.
PROCEDURE
Water Supply Official
Notifies the Field Response Personnel of a toxic chemical problem by
telephone and provides the following information:

a)    Name.
b)    Organization.
c)    Position.
d)    Telephone number.
e)    Name of the chemical agent (trade and/or generic and/or formula)
      and whenever possible the name of the manufacturer.
f)    Amount introduced  or which might be introduced into the source
      of supply or system.
g)    Point of introduction.
h)    Volume of water at point of introduction.
Field Response Personnel 2.     Immediately relays information to the BPWS.
      * Adapted from: New York State Department of Health Engineering and Sanitation Manual Division
of Sanitary Engineering.

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                                                                                          Page N-2
                                      Appendix N (continued)

                              SPECIFIC RESPONSE PROCEDURES
                    Chemicals Accidentally Introduced Into Public Water Supplies
PROCEDURE (continued)

BPWS                   3.




Information Source       4.
BPWS
Field
BPWS
            5.


            6.

            7.

            8.

            9.
Requests lexicological information from the New York State Department
of Health Division of Laboratories and Research; United States Public
Health Service Poison Control Branch, Washington, D.C. (telephone (202)
963-7512); Local Poison Control Center, and/or chemical manufacturer.

Provides the following information:

(a)   The chemical  is not toxic
                 or
(b)   The chemical  is toxic in the following ratios:
      1)    Acute toxieity in mg/1 for a certain period of time.
      2)    Moderate toxieity in mg/1 for a certain period of time.
      3)    Low toxieity in mg/1.

Transmits information to the Field regarding hazards involved and methods
of eliminating the hazard.

Advise the water supply official of action to be taken.

Prepares information memorandum to  BPWS.

Requests laboratory  assistance to establish a surveillance program.

Prepares post-action department report.
 SUPPLEMENTARY INFORMATION

       A.
       B.
Emergency type calls may be placed to the Public Health Service Poison Control
Center Clearinghouse, Washington,  D.C.  (telephone (202) 963-7512) by any
individual concerned, providing that the resolution of the problem is coordinated
with the Field Response Personnel and/or BPWS.

The Local Poison Control Centers primarily provide an information service for
the medical profession concerning the prevention and treatment of accidents
involving ingestion of poisonous and potentially poisonous substances.
                         ••U.S. GOVERNMENT PRIHTIHG OFFICE: 1995-623-709/82257

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