State Emergency Drinking Water Supply Plan Instructions and Template EPA Office of Water (4608T) EPA 817-B-21-002 ------- State Emergency Drinking Water Supply Plan Instructions and Template Introduction During an incident that disrupts the availability of drinking water on a large-scale or regional basis, clarity in the roles and responsibilities of those involved with locating, securing, and delivering an Emergency Drinking Water Supply (EDWS) will be critical. An EDWS Plan is an important tool for a state drinking water primacy agency that will allow for optimum coordination with the state Emergency Management Agency (EMA) and other stakeholders. This will ensure not only safe drinking water for citizens but also compliance with federal regulations under 40 CFR 142, Subpart B. An EDWS Plan maps out emergency water supply needs and other logistics to be coordinated during drinking water incidents. It details how a state will locate, secure, and deliver an EDWS, specifically outlining the roles and responsibilities of local, state, tribal, and federal agencies and other stakeholders. The intent is to meet drinking water needs during an incident quickly and safely, while minimizing duplication of effort. The EDWS Plan instructions and template are targeted at: • State drinking water primacy agencies • State EM As • Regional and local government entities that may assist the state in providing an EDWS In addition to the above, it may be helpful to include others in the planning and development process depending on the needs of your state. These may include non-governmental organizations such as the American Red Cross or private sector entities such as water and beverage distributors. How to Use These Instructions and Template The U.S. Environmental Protection Agency (EPA) has prepared these instructions and template to provide state drinking water primacy agencies a starting point in the development of a state-wide EDWS Plan. The instructions and template were developed based on the California Emergency Drinking Water Procurement & Distribution Planning Guidance (May 2014) and two EDWS state workshops sponsored by EPA in Colorado and Rhode Island. As a result, these instructions and template offer general guidance regarding what states should consider as they develop their individual plans, recognizing that not all elements may be applicable. States should modify the template content to better meet their needs and circumstances. Creating a State Emergency Drinking Water Supply Plan There are no federal requirements for what an EDWS Plan should contain; however, the following steps can help a state begin planning for locating, securing, and delivering an EDWS when needed. One way to accomplish these steps is to convene an EDWS planning workshop or series of workshops with the appropriate stakeholders. W STATE EDWS PLAN TEMPLATE State Emergency Drinking Water Supply Plan ------- Step 1: Bring Together Knowledgeable Stakeholders Developing an EDWS Plan should bring together the experience and knowledge of different local, state, tribal, and federal agencies along with non-governmental organizations and private industries and institutions. Many of these response stakeholders (see Table 1 in Section 3) have experience with emergency planning and can bring knowledge and resources to aid the development of an EDWS Plan. Some response agencies may have plans or protocols that outline existing coordination procedures for providing drinking water during incidents. It will be important to review these documents to determine if the process to locate, secure, and deliver an EDWS is discussed. The State Emergency Operations Plan (SEOP) is an important document to review, as it may already outline processes and procedures for an EDWS. Others might include: • Water Utility Emergency Response Plans (ERP) • County Emergency Operations Plans • Regional Plans Step 2: Understand Roles. Responsibilities, and Resources EDWS planning requires a clear understanding of each stakeholder's role, responsibilities, and available resources (technical and financial) to locate, secure, and deliver an EDWS. During an EDWS planning workshop, existing emergency plans and protocols should be reviewed to understand these aspects, as well as to identify limitations in accessing an EDWS and relevant federal, tribal or state programs. Step 3: Understand Legal. Regulatory, Financial, and Coordination Processes Some entities and stakeholders must follow specific legal and regulatory requirements to locate, secure, and deliver an EDWS. For example, a state's drinking water regulations might require public water systems (PWSs) to maintain some EDWS capabilities. Or the state may need to approve a bulk water hauler in advance of any EDWS delivery. States may also have procedures that must be followed to purchase, acquire, or otherwise gain access to an EDWS. During an EDWS planning workshop, all local, state, tribal, and federal requirements and protocols regarding EDWSs should be discussed and understood prior to developing the plan. Step 4: Identify Duplication of Effort. Vulnerabilities and Gaps Bringing together key stakeholders will reveal where entities may be performing the same EDWS task during incidents or where vulnerabilities and gaps might exist. For example, a water utility might think the local EMA is responsible for providing emergency drinking water, but the local EMA might think the water utility is responsible. Reviewing the SEOP and other protocols and plans at an EDWS planning workshop can be very helpful. Figure 1 on the next page contains a flowchart depicting this four-step process. You may also consider developing a process flowchart to help visually present your EDWS plan both during development and once completed. State Emergency Drinking Water Supply Plan ------- Figure 1. Process for Creating an Emergency Drinking Water Supply Plan Step 1 - Bring Together Knowledgeable Stakeholders • Convene an EDWS planning workshop of all government and non-government stakeholders. • Identity existing emergency plans and protocols that involve an EDWS. Step 4 - Identify Duplication of Effort and Gaps • Determine where efforts are duplicated and can be eliminated, and where comminication gaps might exist in locating, securing, and delivering an EDWS. Step 3 - Understand Legal, Regulatory, Financial, and Coordination Processes • Identify and understand the legal, regulatory, financial, and coordination processes that impact how an EDWS is secured, stored, and distributed. Step 2 - Understand Roles, Responsibilities, and Resources • Develop a clear understanding of roles and responsibilities of all stakeholders. • Outline available technical and financial resources. Updating Your Emergency Drinking Water Supply Plan Your EDWS Plan is a dynamic document and should be revisited regularly to update protocols or procedures and validate information, including roles and responsibilities, names, and contact information (Section 3). A regular review schedule and training (e.g., twice a year) will help to ensure that all plan information is current, and that staff are familiar with the contents and any recent changes to the plan. In addition, you should exercise your EDWS Plan at least annually. Exercises allow you to test and practice the procedures in your plan with response partners prior to any EDWS incident. Additional information on developing a training and exercise plan can be found here. State Emergency Drinking Water Supply Plan ------- TABLE OF CONTENTS 1 Introduction 1 2 State Emergency Operations Plan 1 2.1 SEOP Overview 1 2.2 SEOP Priorities, Goals, and Strategies 1 2.3 SEOP Direction, Control, and Coordination 2 2.4 Intelligence Gathering and Situation Reporting 2 2.5 Public Information 2 3 Roles and Responsibilities 2 3.1 Water Sector Specific Position (WSSP) 4 3.2 Emergency Response Stakeholders 4 4 Emergency Drinking Water Supply Source and Distribution Considerations 5 4.1 Emergency Drinking Water Supply Sources 5 4.2 Emergency Drinking Water Supply Distribution 6 5 Appendices 7 APPENDIX A: References 7 APPENDIX B: Sample Local EDWS Plan 7 APPENDIX C: State Bulk Water Contract and List of Approved Bulk Water Haulers 7 APPENDIX D: State Bottled Water Contracts 8 APPENDIX E: Acronyms 8 APPENDIX F: Glossary 8 APPENDIX G: Emergency Assistance Agreements 8 State Emergency Drinking Water Supply Plan ------- 1 Introduction Briefly describe how the EDWS Plan was developed, listing participating agencies, committees, and other partners and stakeholders as appropriate. Identify the agency that is responsible for maintaining and implementing the plan, along with any agency, committee, or task force that will assist this agency. Purpose Describe the purpose of the EDWS Plan. Some examples from the California Emergency Water Procurement & Distribution Planning Guidance are: • Provide a state response concept of EDWS operations including roles and responsibilities, resource management, and the descriptions of any state and local task forces and committees focused on EDWS. • Enable development of an EDWS Plan that: o Identifies who owns, deploys, and operates EDWS assets, o Overcomes unexpected obstacles during an incident, such as political pressure, o Ensures the availability of local and state EDWS resources. • Provide EDWS planning for the state. • Identify state level programs and resources related to EDWS. 2 State Emergency Operations Plan 2.1 SEOP Overview Provide an overview of your state's SEOP, including the following aspects: • Current process and procedures for emergency management and/or responding to statewide incidents. Highlight how the coordination to locate, secure, and deliver an EDWS is incorporated into these procedures. Even if this information is available, it may be necessary to clarify the roles and responsibilities of the stakeholders involved. • The Emergency Support Function (ESF) under which drinking water is managed. Describe how this ESF is coordinated with local and regional EDWS plans/procedures/entities (as applicable). • Where the SEOP can be accessed (provide links if available). Include a list of the jurisdictional levels in your state. Examples include PWSs, local government (municipal, county, and special districts), regional government (as applicable), and state government. Provide a brief description of how they broadly plan for EDWS incidents and how these plans dovetail with the SEOP (as applicable). 2.2 SEOP Priorities, Goals, and Strategies Provide brief statements about the operational priorities, goals, and strategies listed in the SEOP. Examples are provided below. Highlight those that focus on an EDWS (as applicable). • Property Protection • Environmental Protection • Restoration of Essential Utilities and Program Functions Page 1 | State Emergency Drinking Water Supply Plan ------- 2.3 SEOP Direction, Control, and Coordination Describe who is responsible for emergency response based on statutory authority. The SEOP will most likely list all state entities and their responsibilities for various kinds of emergency incidents. Highlight those entities that assist efforts associated with an EDWS, as applicable. 2.4 Intelligence Gathering and Situation Reporting Describe how information is managed, shared, and reported both during and after the incident. Briefly describe the process outlined in the SEOP, including anything that might be specific to EDWS, if discussed. 2.5 Public Information Describe how information about an incident will be communicated with the public, including coordination with other responders, focusing on EDWS incidents if discussed. 3 Roles and Responsibilities During a statewide incident that disrupts the ability of local PWSs to provide drinking water, your EDWS plan should provide clear direction on the roles and responsibilities of stakeholders. List all response stakeholders at all jurisdictional levels in your state and detail the functions they would perform during an EDWS-related response. Highlight available emergency response resources (e.g., labor, technical, material, financial) and the appropriate contact person(s). Contact information and available resources should be updated periodically to ensure the plan is current. This list of response stakeholders (Table 1) should be reflective of those participating in the development of the EDWS Plan, including (see next page): NIMSand ICS All domestic incidents in the United States are managed under the National Incident Management System (NIMS). NIMS guides all levels of government, NGOs, and the private sector to work together to prevent, protect against, mitigate, respond to, and recover from the effects of incidents. Under NIMS, local on-scene incident management is accomplished through the Incident Command System (ICS). If you are not familiar with NIMS and ICS, the Federal Emergency Management Agency (FEMA) offers free on-line training here. EPA also offers training that can be found here. Page 2 | State Emergency Drinking Water Supply Plan ------- Table 1. Response Stakeholders Local Level • Public Water Systems (PWSs) • Municipal or County Government • Local Law Enforcement • Local Health Department • Local Emergency Management Agency • Local Emergency Planning Committee State/Tribal Level • State Primacy Agency for Drinking Water • State Emergency Management Agency • State Public Health Department • State Environmental or Engineering Agency • State National Guard • State Department of Transportation • State Law Enforcement • State Emergency Response Commission • Governor's Office • Tribal Primacy Agency for Drinking Water • Tribal Council • Tribal Emergency Management Agency Mutual Aid and Assistance/ Federal Level Nongovernmental Organizations Private Sector • U.S. Environmental • Water and Wastewater • Private Utilities Protection Agency Agency Response Network • Industries • Federal Emergency (WARN) • Corporations and Management Agency • National Rural Water Businesses • U.S. Army Corps of Association (NRWA), • Professional and Trade Engineers American Water Works Associations Association (AWWA), Rural Community Assistance Partnership (RCAP) • Academic Institutions (e.g., universities, colleges) Hospitals • Community-based and • faith-based organizations, such as the American Red Cross and Salvation Army There is no standard way to present this information in an EDWS Plan, but it should be clear and concise. Some of this information can be found in the emergency plans of others, such as your SEOP and other state agency-specific plans. Overarching federal roles and responsibilities are outlined in the Page 3 | State Emergency Drinking Water Supply Plan ------- National Response Framework. The EDWS Plan template includes a table as an example of how this information can be organized and displayed. 3.1 Water Sector Specific Position (WSSP) Coordination of an EDWS during an incident is further helped with the designation of a Water Sector Specific Position (WSSP) at both the state emergency operations center (SEOC) and local EOCs. A WSSP can be a Water Sector Liaison, Drinking Water Coordinator, or Technical Specialist for drinking water issues. WSSPs (and their assistants as needed)can serve as the primary contact and coordinator during drinking water incidents. Your EDWS Plan should outline the role of this individual and any support staff. In some states, a member of the state Water and Wastewater Agency Response Network (WARN) may already serve in this role at the SEOC. You should also encourage water utilities to work with their local emergency managers to establish this position in local EOCs. Figure 2 above provides an example of some of the roles and responsibilities of a WSSP. Be the primary EOC contact for all EDWS procurement and distribution matters WSSP Coordinate with primacy agency, PWSs, and others for appropriate public information announcements and media outreach Work with affected PWSs, prioritize distribution locations, and recommend options for EDWS procurement and distribution Identify transportation and equipment needs and secure required Identify and secure drinking water resources Figure 2. Water Sector Specific Position 3.2 Emergency Response Stakeholders Describe the roles and responsibilities of stakeholders involved in the response to an emergency event that requires an EDWS. Include the available resources from that stakeholder and contact information. Page 4 | State Emergency Drinking Water Supply Plan ------- 4 Emergency Drinking Water Supply Source and Distribution Considerations Planning for an EDWS source and distribution requires the state drinking water primacy agency to consider many factors, including legal and regulatory aspects. For example, if bulk hauling of water in tanker trucks is an option, what is the approved source of that water? And, once on-site, is water quality testing required prior to distribution? Will waivers from any of the Federal Motor Carrier Safety Regulations be needed to ensure water haulers can stay on the road? Funding is another important planning consideration. You should have a conversation with your state EMA regarding funding, as they may have an EDWS funding strategy in place. Also, how much EDWS will be needed? FEMA and the Centers for Disease Control and Prevention (CDC) recommend one gallon of drinking water per person per day as a minimum planning requirement. Additional water is recommended for pets, cooking, and bathing. Critical infrastructure including health care facilities (e.g., hospitals, skilled nursing facilities) require larger amounts of water to maintain operations within the community and should be considered separately. You should encourage local water utilities in your state to contact their critical customers to determine what EDWS plans they may already have in place. Additionally, be aware of what plans drinking water utilities in your state may already have to provide an EDWS. Some may have implemented EPA's guidance for providing EDWS during large-scale disasters. Each state and incident are different, and your EDWS Plan should outline any source and distribution considerations to ensure that all options and their associated circumstances are understood by agency decision makers. 4.1 Emergency Drinking Water Supply Sources Identify the EDWS options available and the planning considerations for securing each. List as many available options in your EDWS Plan as necessary, adding details as needed for implementation, including references to state or local protocols. Examples include: • Treatment of available source water • Packaged or bottled water • Bulk/hauled drinking water • Emergency interconnections with neighboring systems • Other options (e.g., EDWS contracts held by your state contracting agency, interstate sources obtained through the Emergency Management Assistance Compact) Reimbursement During a Presidentially declared disaster, reimbursement for EDWS by local or state agencies is permitted under FEMA's Public Assistance program. Page 117 of FEMA's Public Assistance Guidance describes this reimbursement for supplies and commodities further. This reimbursement eligibility for EDWS may influence how your state and the local agencies within your state prepare for EDWS procurement and distribution. Page 5 | State Emergency Drinking Water Supply Plan ------- As appropriate, provide reference links or attach documents to the EDWS Plan as appendices. Figure 3 describes EDWS sources that may be considered as you complete this section of the template. Figure 3. Potential EDWS Sources Treatment of Available Source Water If the PWS treatment system is down, alternate treatment of the source water may be an option. Planning considerations could include PWS consultation with the state drinking water primacy agency for prior approval of options such as using a commercial portable water treatment system. Packaged or Bottled Water Planning for packaged or bottled water should consider available partners (e.g., to help with purchasing and/or storing water). Your state emergency management agency may already have plans for this. Bulk/Hauled Drinking Water Consideration for bulk water haulers must include state regulations, policies, and best management practices in addition to federal rules governing commercial driving licenses. Understand what the water source is and how it will be transported to needed areas. Determine if your state could negotiate a master agreement with a local distributor for EDWS. Emergency Interconnections with Neighboring Systems Interconnections with neighboring PWSs may require approval by the state drinking water primacy agency. This should be established as early as possible in EDWS planning, particularly if capital investments are required. There may be opportunities for temporary interconnections above or below ground under emergency conditions. Other Options Other options for an EDWS might include hydrant tapping, which would require coordination between the PWS and state. Drilling new wells or developing other alternate sources might also be considered, which requires more long-term planning and development. 4.2 Emergency Drinking Water Supply Distribution Determine the factors that will impact the distribution of an EDWS and how you will plan for these considerations. Examples include: • Operational drinking water distribution system (treatment system is down) • Non-operational water distribution system o Transport o Points of distribution Planning considerations include how and where an EDWS will be distributed to customers, needed agreements at points of distribution or "PODs" (e.g., a Memorandum of Understanding regarding which agency staffs and operates a POD), and identifying potential jurisdictional conflicts or competing uses at POD sites (e.g., has the site also been designated as an air lift site for medical emergencies?). Other interdependencies should be considered as well, such as power and fuel supply. Figure 4 on the next page further describes EDWS distribution considerations as you complete this section of the template. Page 6 | State Emergency Drinking Water Supply Plan ------- Figure 4. EDWS Distribution Considerations Operational Drinking Water Distribution System If a PWS's distribution system is still operational and will be used to distribute EDWS, planning considerations include the configuration of the system in the affected area, interconnectivity with neighboring systems, availability of valve control options for isolating systems, rerouting water, and identifying and installing the alternate treatment system for the avaiable source water. Non-operational Water Distribution System When a water distribution system is no longer operational, the logistics of distributing EDWS (e.g., bottled or bulk water) to affected populations may pose significant challenges. Factors to consider in distribution include the transport of water to PODs as well as who will staff and provide security at PODs. Transport Packaged water must be transported from its storage location to PODs. In some cases, water from existing treated water reservoirs can be pumped into tankers or packaged on-site to meet customer needs. Logistical concerns include fuel, clear roadways and planning for forklifts to load pallets on/off trucks. Points of Distribution PWSs/local governments and other organization that provide EDWS should identify the locations for EDWS distribution and negotiate agreements for location and use. Special care should be taken to avoid jurisdictional conflicts and competing uses. For example, PWSs and local governments may require agreements at potential EDWS POD sites (such as a parking lot of a local shopping center) to avoid any misunderstandings or conflicts regarding use. 5 Appendices The following appendices are examples to consider including in an EDWS Plan. Your plan can include as many appendices as appropriate to provide quick access to needed information during a drinking water emergency. APPENDIX A: References Include important local, regional, and state planning documents, regulations, or other protocols that affect EDWS and links to where they can be found online. Your SEOP should be listed here. APPENDIX B: Sample Local EDWS Plan If available, include a local EDWS plan that can serve as a model for your agency to share with PWSs and local jurisdictions as needed. APPENDIX C: State Bulk Water Contract and List of Approved Bulk Water Haulers If available, include your state's bulk water contract and list of approved bulk water haulers. Include any regulations, policies and industry-related best practices that apply to bulk water haulers. Page 7 | State Emergency Drinking Water Supply Plan ------- APPENDIX D: State Bottled Water Contracts If available, include your state's bottled/packaged water contract(s) here. This may be maintained by your state Emergency Management Agency. APPENDIX E: Acronyms Include a list of acronyms for commonly used terms in the EDWS plan. A starter list is provided. APPENDIX F: Glossary Include a list of terms and phrases used throughout the EDWS plan and their definitions. A starter glossary is provided. APPENDIX G: Emergency Assistance Agreements Include here copies of any available local, regional, state, tribal, and federal assistance agreements or documents (e.g., Memoranda of Understanding) that support your state during a drinking water emergency. Examples are provided in the template. Terminology may be different in your state. Page 8 | State Emergency Drinking Water Supply Plan ------- |