&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 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
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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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Exhibit 2-2
EXAMPLE OF A SCHEMATIC DIAGRAM
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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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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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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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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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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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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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• 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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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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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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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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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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• 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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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• 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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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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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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• 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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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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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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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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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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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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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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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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• 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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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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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)
-------
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
-------
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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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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