emergency response plan Archives

Water Systems Under Pressure: Planning for Emergencies

When the pressure is high and response time is short, a well-structured emergency response plan (ERP) becomes the foundation of an effective, coordinated action plan. It ensures everyone involved understands their role, knows how to communicate, and has access to the resources they need to restore service quickly and safely.

To build that kind of clarity and coordination, you need to start with the fundamentals.

ERPs: Who, What, Where, When, and Why

When we talk about planning for emergencies, it helps to go back to the basics. Every effective ERP should clearly address the who, what, where, when, and why—not just in theory, but in practice.

Who: All those essential to coordinated response, including utility staff, emergency responders, regulators, and local officials;
What: Identifies threats and outlines specific emergency response procedures, such as floods, contamination, or system failures;
Where: Training and drills can occur onsite, virtually, or in classrooms; the EPA also offers tools and templates online;
When: Activated during any threat; must be reviewed regularly and recertified every 5 years; and
Why: To protect public health, ensure service continuity, and meet regulatory requirements.

A well-balanced and robust ERP also goes beyond these basics and typically includes, but is not limited to, the following:

Utility and personnel information;
Communication strategies for notifying the public and stakeholders;
Contingency plans for alternative water sources;
Distribution and service continuity procedures; and
Threat detection strategies and incident response protocols.

Together, these components ensure that when an emergency strikes, utilities can respond swiftly, effectively, and with confidence.

Time is of the Essence

Too often, ERPs are treated as static documents and are only revisited when either required by a regulation or after an incident. However, emergencies rarely occur during convenient moments of downtime, or in line with regulatory deadlines. Given the unpredictable nature of emergencies, ERPs need to be living documents that not only evolve with a team, but with infrastructure and the threats an organization or industry faces.

In fact, the United States Environmental Protection Agency (EPA) agrees. Under the America’s Water Infrastructure Act of 2018 (AWA), all public water suppliers that serve populations of more than 3,300 are required by the EPA to not only develop an ERP, but also to complete a Risk and Resilience Assessment (RRA) — and both the ERP and RRA must be updated every five years at a minimum. Because initial assessments were conducted about five years ago, utilities serving populations over 3,300 are due to update their RRAs and ERPs by the following dates:

Over 100,000 population: RRA certification was due March 31, 2025, and ERP certification is due September 30, 2025.
50,000–99,999 population: RRA certification is due December 31, 2025, and ERP certification is due June 30, 2026.
3,301–49,999 population: RRA certification is due June 30, 2026, and ERP certification is due December 31, 2026.

If your utility’s RRA or ERP hasn’t been updated or has yet to be tested through training or drills, we strongly suggest scheduling your review now in order to meet the above deadlines.

What You Need and What That Involves

When it comes to developing or updating an ERP, it requires a methodical approach. While each utility is unique, there are several core components that need to be addressed to ensure a level of preparedness that is fit for a wide variety of emergency scenarios.

To start, there must be a thorough inventory of critical infrastructure. This includes treatment facilities, pump stations, and other essential assets. Each of these should be assessed for potential vulnerabilities and prioritized according to their impact on the operation. This first step is crucial in creating an ERP that ensures not only continuity of service, but minimizes downtime during emergencies and efficiently allocates the necessary resources to protect the water system’s most vital components.

Next is communication planning. An effective ERP will outline how internal teams, external stakeholders, public officials, and the general public will be informed during an emergency. It will also account for any possible disruptions, such as power outages or internet disruptions, and identify communication tools, contact protocols, and responsibilities for the spokesperson that are needed to keep communication flowing.

The communication planning then ties neatly into detailing clearly defined roles and responsibilities. Everyone on a utility’s team, from operators to administrative staff, should understand their responsibilities during different types of incidents. This includes identifying a chain of command, assigning alternates, and maintaining an up-to-date contact list.

Mutual aid agreements should also be reviewed and documented during the ERP-creation process. In many emergencies, collaboration with nearby utilities, contractors, or regional agencies can truly make all the difference between a short disruption and a prolonged service outage. These agreements outline shared resources, personnel, and equipment, and should be maintained as part of your ERP.

Training and exercises are just as essential. Tabletop drills, field exercises, and even partial walk-throughs can greatly help reinforce your team’s familiarity (and confidence) with procedures, identifying areas where the plan may fall short.

An often forgotten component to an ERP is cybersecurity. This aspect has become increasingly important as systems and customer data have moved over to digital platforms. ERPs must account for cyber threats just as seriously as they do physical ones. An ERP should include strategies for isolating affected systems, maintaining operations manually if deemed necessary, and engaging with external support if a breach occurs.

Finally, thorough documentation is key. An ERP should be easy to access in both digital and physical formats, clearly organized, and readily available to anyone who may need it during an emergency.

Facing the Pressure with Confidence

There is no question that today’s water systems are under pressure; however, adequate preparation can greatly affect the outcome. With a well-designed, robust, and up-to-date ERP in place, utilities are equipped to protect public health, minimize service disruptions, and recover quickly from emergencies.

At Tata & Howard, we specialize in helping utilities develop and refine ERPs that go beyond compliance. Our team brings practical insight, regulatory knowledge, and years of hands-on experience to support your emergency planning efforts; from vulnerability assessments to training and implementation. Contact us today to schedule your ERP preparation or training.

ERP in Action

T&H client Cherry Valley recently put their ERP into action when disaster struck. Learn how they were able to successfully navigate the emergency by implementing their ERP.

Water Utilities: Working Toward a Healthier Future

In today’s modern world, it’s fair to say that water utilities operate as the guardians of public health, constantly staying vigilant against threats to water quality, safety, and accessibility.

While their efforts may often go unnoticed by the general public, behind the scenes, water utilities are continuously improving their systems and operations to enhance safety and health standards for the public. From infrastructure upgrades and quality testing to innovative solutions and emergency preparedness, all are instrumental in enhancing the overall well-being of our community.

Infrastructure Upgrades

Water utilities’ relentless pursuit of minimizing leaks, contamination risks, and disruptions in water supply are at the forefront of modernization, specifically when it comes to the upgrading of pipelines, treatment plants, and distribution system components. With these crucial infrastructure updates, often a product of the combined efforts of water audits and utility management, utilities are able to decrease the need for new sources, treatment plants, facility upgrades, and expansions and reduce the number of entry points for disease-causing pathogens.

Through these passion-fueled, robust efforts, these upgrades become the backbone of a resilient and reliable water infrastructure, further increasing the safety and accessibility of public water.

Quality Testing and Monitoring

Ensuring the safety of water begins with a commitment to quality testing and monitoring. Water utilities that conduct meticulous lead inventories and testing procedures are able to swiftly identify potential risks, because as we know, lead is not our friend. By vigilantly tracking water quality, utilities safeguard communities from the harmful effects of these contaminants. They also maintain a constant awareness of the condition of our public infrastructure, gaining insights into both successes and areas that require improvement.

According to the World Health Organization, one million people die every year due to lead poisoning. Whether it’s from industrial settings, like mining and smelting, or paint and plumbing in older homes, lead poisoning maintains its spot as a high risk that can be mitigated by routine replacement of lead service lines.

Innovative Solutions

The relentless pursuit of improvement and modernization embraced by Tata & Howard helps water utilities further pave the way towards embracing more cutting-edge technologies and innovative solutions. In addition, Tata & Howard is a 100% Employee Stock Owned Plan (ESOP) company, meaning that the collaborative nature of the client-ESOP firm relationship allows for both parties to explore and embrace more unconventional, innovative solutions: solutions such as advanced filtration systems and real-time monitoring, both of which can also be catered to our customers’ specific and individual needs.

Emergency Preparedness

As “guardians of public health,” water utilities also serve as sentinels, always prepared for the unexpected. The level of preparedness in their Emergency Response Plans (ERPs) allows for a swift and coordinated response to natural disasters, industrial accidents, or disruptions in the water supply.

In fact, all public water suppliers are required to have ERPs in place. Public water systems in Massachusetts are also obligated to conduct a minimum of 10 hours of Emergency Response training each year for their employees which plays a crucial role in enabling water system managers and staff to identify vulnerabilities, implement improvements, and establish effective procedures to be followed in case of an emergency.

The (mandated) preparation, continuous updating, and execution of a response plan are essential for strengthening system security, reducing property damage, minimizing liability, preventing illnesses, and saving lives.

Conclusion

As water utilities continue to evolve and collaborate on the continuous efforts of upgrading infrastructure, embracing innovation, and prioritizing emergency preparedness, the more secure they — and we as a community — are in the vital role they play in ensuring the availability and accessibility of clean and safe water.

Amidst the challenges we face as we navigate the modern world, let us not forget to acknowledge the relentless dedication of these guardians – the water utilities that quietly, yet profoundly, secure the health and safety of the communities they serve.

Emergency Preparedness

Why Staff Needs to Know the Plan Ahead of Time

Benjamin Franklin once said, “by failing to prepare, you are preparing to fail.” While this remains true for all facets of life and community responsibility, the notion of emergency preparedness is critical, particularly within the water sector. Emergency preparedness strategies are designed to ensure that all processes can run smoothly during a crisis, and that clean, safe drinking water and sanitary services will continue to be provided to customers.

The most common (and required) method of emergency preparedness for water suppliers and utilities are Emergency Response Plans (ERP). ERPs are mandatory for all public water suppliers, and public water systems in Massachusetts are required to provide a minimum of 10 hours of Emergency Response training annually for all employees. Trainings help water system managers and staff explore vulnerabilities, make improvements, and establish procedures to follow during an emergency. Preparing and implementing a response plan can save lives, prevent illness, enhance system security, minimize property damage, and lessen liability.

There are many components to an ERP, each playing a key role in mitigating issues.

EPA Certification Form
Introduction
Response Plans
Emergency Planning
Mitigation
Emergency Response Plan Policies
Water System Policies
Telephone Contact Numbers
Critical Customers
System Information
Emergency Action Plans
Incident Specific Emergency Action Plans
Safety Data Sheets (SDS)
Interconnection Agreements
Standard Operating Procedures
Comprehensive Flushing Program

Outside of ERPs, many utilities are finding it helpful to implement additional emergency preparedness initiatives into their ERPs. Whether the crisis is a pandemic, a flood, or a natural disaster, keeping staff educated, informed, and in the loop will prevent additional issues from arising during an emergency.

By asking the right questions and preparing in advance, your utility can clarify the roles and responsibilities of personnel and identify any additional mitigation measures and preparedness needs.

Some important questions to raise in implementing additional emergency preparedness measures include:

Does the utility have all of the proper written protocols in place?
Has the utility defined all critical positions?
Have back-ups been identified for each critical position?
How do we keep staff safe?
Are there opportunities for improvement?
Are there gaps in knowledge of personnel, health and safety measures, or security that should be improved upon?

By answering these and other questions, a plan can be developed and easily followed by all staff members. A solid and well thought out plan leaves little room for interpretation and clearly defines roles and responsibilities, as well as the hierarchy of authority.

Once the emergency preparedness measures are in place, be sure that all staff and personnel are informed and properly trained. This will eliminate panic and provide additional assurance should a crisis arise in the future. Additionally, if staff are prepared and aware of their roles and responsibilities, there will be a smaller gap in service for customers.

Benefits to staff in being prepared for emergencies include:

Decreased feeling of vulnerability
Reduction of fear and anxiety
Confidence in roles and responsibilities
Increased awareness of utility’s commitment to the safety of the team
Knowing what to expect

Interested in implementing additional emergency preparedness training within your utility? Tata & Howard offers several training options and formats including:

ERP Training
Tabletop Exercises

For more information, please contact Karen Gracey at kgracey@tataandhoward.com or 508. 219.4021.

Michael F. Knox Joins T&H as Client Service Specialist

Water and Wastewater Professional Mike Knox to Run Emergency Response Training Programs

Tata & Howard, Inc., a leading innovator in water, wastewater, and stormwater engineering solutions, is pleased to announce that Michael F. Knox, has joined the firm as a Client Service Specialist. In this newly created role, Mr. Knox will concentrate on developing Emergency Response Training Programs to be offered starting this fall.

Prior to joining Tata & Howard, Mr. Knox worked as the Superintendent and Chief Operator for the Cherry Valley and Rochdale Water & Sewer District in Leicester, Massachusetts. He holds a 2C and 3T drinking water license and a 3M wastewater license, and he has a B.S. in Mechanical Engineering.

In addition, Mr. Knox served as a member of the Massachusetts Water and Wastewater Agency Responses Network (MAWARN) Steering Committee and was the MAWARN Chair from 2008 to 2011. He is a member and Past President of the Massachusetts Water Works Association (MWWA).

“As a former Superintendent and Chief Operator of a Water & Sewer District, Mike brings a unique perspective to this position,” Paul B. Howard, P.E., T&H Senior Vice President stated. “Having worked with Mike in the past, we knew of his experience and expertise improving the safety and security of municipal assets and implementing emergency response programs.”

“We’re excited to have Mike on our team,” Karen L. Gracey, P.E., T&H Co-President said. “Mike’s knowledge and thorough understanding of critical emergency response methodologies and training skills will not only benefit municipal water operations but also help improve their service to the community water systems they manage.”

Emergency Response Plans (ERPs) are mandatory for all public water suppliers, and a minimum of 10 hours of Emergency Response Training is required. ERP training is a process that helps water system managers and staff explore vulnerabilities, make improvements, and establish procedures to follow during an emergency. Preparing and practicing an ERP can save lives, prevent illness, enhance system security, minimize property damage, and lessen liability.

SaveSave

The West Virginia Water Crisis: a Warning for our Future

Over the past several days, over 300,000 consumers in West Virginia have been unable to use their tap water for any purpose other than toilet flushing due to a chemical leak from coal manufacturer Freedom Industries. The chemical, 4-methylcyclohexane methanol (MCHM), was stored in antiquated 40,000 gallon tanks very close to the Elk River. You can read about the leak here: https://nbcnews.to/1hT9Iz9

Questions are certainly being raised surrounding this crisis. Could it have been handled better? Could it have been avoided altogether? And finally, is there a way to prevent this type of disaster from happening again? And the answer to all is an unequivocal yes.

First, there are no regulations for MCHM, even though some warning flags had been raised. From the Charleston Saturday Gazette-Mail:

Last February, Freedom Industries sent state officials a form telling them the company stored thousands of pounds of a coal-cleaning chemical called 4-methylcyclohexanemethanol in the storage tanks at its Etowah River Terminal.

The facility, along the Elk River not far from downtown Charleston, is about 1.5 miles upstream from the intake West Virginia American Water uses to supply drinking water for 300,000 residents across the capital city and the surrounding region.

Freedom Industries filed its “Tier 2” form under the federal Emergency Planning and Community Right to Know Act. State emergency response officials got a copy. So did emergency planners and responders from Kanawha County.

Under the law, government officials are supposed to use chemical inventory information on Tier 2 forms, like Freedom Industries’, to prepare for potential accidents.

Armed with the forms, they know what facilities could explode, where large quantities of dangerous substances are stockpiled, and what industries could pose threats to things such as drinking water supplies. They can plan how to evacuate residents, fight fires or contain toxic leaks.

On Thursday morning, an unknown amount of the chemical leaked from one of Freedom Industries’ tanks into the Elk River. By late afternoon, West Virginia American Water was warning residents across a nine-county region not only not to drink their water, but also not to use it for anything except flushing toilets or fighting fires.

Now, all manner of federal, state and local agencies are rushing to truck in water and otherwise see to residents’ needs, following Gov. Earl Ray Tomblin’s declaration of a “state of emergency” and President Obama’s order to provide federal assistance.

Those same agencies and public officials, though, have said they know little about the chemical involved. They’re all acting a bit surprised that this mystery substance was being stockpiled so close to a crucial water intake, and shocked that something like this could have happened.

Clearly, state officials were well informed on the location and volume of MCHM near a public water supply, yet they took no action, not even to inspect the tanks. And the reason is simple: there is very little information on the level of toxicity of MCHM, and it is therefore not regulated.

Freedom Industries’ tanks do not fall under any jurisdiction and do not require any type of inspection because MCHM is not considered hazardous enough to require permitting, even though it causes skin irritation as well as nausea and vomiting. In fact, Freedom Industries wasn\’t under any type of state oversight, said Michael Dorsey, Chief of the State Department of Environmental Protection’s Homeland Security and Emergency Response office.

“In my world – I’m a hazmat guy – this stuff’s below my radar screen until this happens,” said Dorsey. “The tanks themselves, we don’t have the regulatory authority to inspect those tanks.”

Fortunately, that is likely to change. Department of Environmental Protection Secretary Randy Huffman noted, “We are working on some ideas right now. I think a lot of folks will be calling for legislation and rightly so.”

In addition, Freedom Industries themselves failed the public in two ways. First, company executives knew full well that the tanks and retaining walls – dating back to the 1930’s and 40’s – were antiquated and desperately needed replacement. Multiple holes up to one inch in diameter were clearly visible in the tanks and walls, and it is generally accepted that the leak into the water supply was two-fold, through holes in both a tank and a retaining wall. Freedom Industries, in full knowledge of the chemicals they stored, the proximity to the public water supply, and the poor condition of their tanks and walls, clearly operated with gross negligence by failing to replace said tanks and walls. But their negligence doesn\’t stop there.

Freedom Industries did not report or respond appropriately. State law mandates immediate reporting of any chemical spill, yet state environmental workers arrived at the spill site at 11:15am on Thursday because of a phone call from West Virginia American Water Company – not Freedom Industries, said Huffman. The water company, who had received complaints from local residents about a licorice-like smell in the water starting at around 7:30am, was quick to alert authorities. Conversely, Freedom Industries was also aware of the leak yet failed to report it. Two Freedom Industries employees noted the smell as well as the leak at around 10:30am and informed company president Gary Southern, who did not report the spill or attempt any type of containment. This inaction very well may have exacerbated an already dire situation.

“Had they put containment measures in place the instant they knew, it’s logical to deduce that there wouldn’t have been as much product in the stream,” Huffman said.

In response to this gross negligence, there have already been six lawsuits filed against Freedom Industries. On January 13, the DEP demanded that Freedom Industries cease its operation and immediately conduct integrity tests of all storage tanks and secondary containment structures, and on Wednesday, January 15, the DEP issued five citations against Freedom Industries.

Lastly, there was no plan in place for dealing with such an emergency. The EPA mandates an Emergency Response Plan (ERP) as well as training for utilities servicing over 3,300 customers in case of emergency. The Bioterrorism Act, which went into effect in 2002 in response to the terrorist attacks of September 11, 2001, requires the preparation of an initial ERP, but not its maintenance. The EPA has noted that an ERP is a living document that should be updated annually at a minimum. Without these updates, an ERP quickly loses its efficacy. A sampling of required action items within an ERP include partnerships with law enforcement, public health officials, emergency workers, and first responders from local to federal levels; general emergency response policies and procedures; identification of alternative water sources; chain-of-command chart; communication procedures and notification lists; personnel safety; property protection; training, exercises, and drills; assessment; and general and incident-specific emergency action procedures. Clearly, an ERP is a comprehensive and crucial tool in maintaining public safety and in mitigating damage and difficulty in times of emergency.

The water crisis in West Virginia was certainly stressful and inconvenient, impacting local residents and businesses both emotionally and financially. However, West Virginians are fortunate that the leaked chemical was not overly toxic and that, so far, nobody has suffered any long-term effects or lost their life. Hopefully, this crisis will be limited to an inconvenience and used as a warning of how we need to be better prepared in case of a serious water-related emergency. Americans take running water for granted, and we don’t realize our dependence on it until disaster strikes. State and federal agencies need to mandate regulations and inspections to prevent such a spill from reoccurring, and water supplies must update and maintain their ERPs. Because let’s face it: water is something that we simply cannot live without.

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