Emergency Preparedness – Why Staff Needs to Know the Plan Ahead of Time

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.

While many utilities may be more prepared now than at the start of the pandemic, additional work may be needed to document plans and procedures. By preparing written plans, a utility can be stronger and more prepared for any emergency or crisis.

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.

Risk & Resilience Assessments And ERPs

Questions Concerning New AWIA Requirements? We’ve got answers.

Community water systems that serve more than 3,300 people are required to complete a Risk and Resilience Assessment as well as develop an Emergency Response Plan (ERP) under Section 2013 of America’s Water Infrastructure Act (AWIA) of 2018.

What is a Risk and Resilience Assessment?

Risk and Resilience Assessments evaluate the vulnerabilities, threats, and consequences from potential hazards, including:

  • Natural hazards and malevolent acts
  • Resilience of water facility infrastructure
  • Monitoring practices
  • Financial systems
  • Chemical storage and handing
  • Operation and maintenance

With this new requirement, utilities must conduct the assessment and submit certification of its completion to the U.S. EPA by:

  • March 31, 2020 if serving >= 100k people
  • December 31, 2020 if serving 50k-99,999 people
  • June 30, 2021 if serving 3,301 to 49,999 people

When do water utilities need to get their Risk and Resilience Assessments re-certified?

Your utility must review the Risk and Resilience Assessment and submit a re-certification to the U.S. EPA every five years.

What is included in an ERP for drinking water utilities?

ERPs are critical for drinking water utilities as they provide plans and procedures for responding to a natural hazard or malevolent act that threatens safe drinking water. Preparing and practicing an ERP can save lives, prevent illness, enhance security, minimize property damage and lessen liability. Included in the plan are actions and identified equipment that are necessary to lessen the impact of a natural hazard, including alternative water sources and the relocation of intakes and flood protection barriers.

When do water utilities need to certify completion of their ERPs?

After completion of the risk and resiliency assessment, utilities must develop or update an Emergency Response Plan and certify completion to US EPA no later than six months after the risk and resiliency assessment certification.

When do water utilities need to get their ERPs re-certified?

Within six months of submitting the re-certification for the risk and resilience assessment, utilities must certify they have reviewed and, if necessary, revised, their emergency response plan.

Where can I find more information?

The U.S. EPA has a wealth of information on their website regarding these two new requirements. Use the links below to learn more.

Tata & Howard Can Help

Tata & Howard offers consulting services to assist water suppliers in completing the Risk and Resilience Assessment as well as update Emergency Response Plans to meet AWIA requirements. In addition, Tata & Howard offers flexible, one- and two-day training programs to assist water utilities and operators in obtaining the required ERP training. Training programs are approved for 7 Training Contact Hours by the MA board of Certification of Operators of Drinking Water Supply Facilities.

For additional guidance, assistance with meeting the AWIA requirements, or to schedule an ERP training session, please contact Michael Knox, Client Service Specialist at 508.925.7559 or by email at MKnox@TataandHoward.com.

Michael F. Knox Joins Tata & Howard as Client Service Specialist

Michael F. Knox Joins Tata & Howard 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.

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The West Virginia Water Crisis: a Warning for our Future

no water sign

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 plant along Elk River, Lawrence PierceFreedom 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.

emergency responseLastly, 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.