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Requirement to Report Changes in Contact Information;
Emergency Preparedness Requirements
Leslie ShurtleffPWS Security Specialist
Drinking Water ProgramDept. of Environmental Conservation
Sustained Compliance: What It Means to Public Water System Owners and Operators
Anchorage, AKSeptember 23-24, 2010
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Outline
Requirement to report changes in contact information to the Program
Emergency Contact Lists & Communication Procedures
Proposed Emergency Preparedness Regulation
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Report Changes in Contact Information
Reporting Requirement:
18 AAC 80.355 (f)
Within 30 days after a change in facility name, ownership, operator, address, or status, the owner or operator shall notify the department, in writing, of the change.
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Report Changes in Contact Information
Required - report in writing a change in:
1. Owner(s)
2. Operator(s)
3. Address
4. Facility Name
5. Status
Point of Contact
Method of Contact
Facility Information
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Report Changes in Contact Information
Change in Owner(s) Operator(s)
Designated Operator in Charge?
Emergency Contact Administrative Contact Financial Contact Legal Contact
Point of Contact
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Report Changes in Contact Information
Change in Address Phone Numbers Fax Numbers Email Address Cell Phone Numbers
Method of Contact
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Report Changes in Contact Information
Common Slip-ups Assumption Inform a different DEC Program Simply forget
Risk being in violation of the requirement
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Report Changes in Contact Information
The little effort it takes to report changes in contact information could prevent major headaches….
The Drinking Water Program (Program) must be able to reach system personnel quickly: • Compliance & Sampling issues• Emergency notifications• Changes in requirements
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Does Your System Maintain a Current Contact List of its Own?
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Establish Communication PathwaysIncrease Preparedness
Emergency Contact Lists Names, Titles, Landline, Cell Phone, Email, Address,
Pager During an incident, normal communication channels
may not be accessible!
1) Internal – System personnel• Assign roles and responsibilities
Chain of Command, ER Lead
2) External – Non-system personnel
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Establish Communication PathwaysIncrease Preparedness
External Emergency Contact List Critical Customers Local Emergency Responders (Police, Fire, EMT, etc.) Vendors for Replacement Equipment & Chemical Supplies Alternate Water Suppliers Power Utility, Gas/Oil Supplier Drinking Water Program Local Emergency Planning Committee Local & State Public Health Dept. Mutual Aid Partners
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Establish Communication PathwaysIncrease Preparedness
Build rapport with entities on external communication list
Establish procedures for when and how to: Request aid from external entities Notify users, related agencies, and the media
• Discuss the condition of water quality, water availability, and how to obtain water from the alternate source
ERP: 8 Core Universal Elements
System Specific Information
PWS Roles and Responsibilities
Communication Procedures
Personnel SafetyIdentification of Alternate Water SourcesReplacement Equipment/Chemical Supplies
Property Protection
Water Sampling and Monitoring13
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Emergency Preparedness Requirements
Current Requirements
Bioterrorism Act of 2002 One time requirement No updates Not pertain to new systems, or systems that
grow to serve 3,300
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Emergency Preparedness Requirements
New state regulation has been drafted, intended to enhance water system preparedness
Anticipated to be available for public comment in 2011
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Emergency Preparedness Requirements
Objective of proposed regulation
Inspire PWS personnel to develop a plan, which will ensure the continuation of drinking water availability in the event the standard system source and/or treatment method is compromised
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Emergency Preparedness Requirements
Development Of Regulation
1) Identify Preparedness Ideal
Every system shall ….• Perform a Security Vulnerability
Assessment (VA)• Develop an Emergency Response
Plan (ERP)
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Emergency Preparedness Requirements
Security Vulnerability Assessment Characterizes the system Considers likely threats Evaluates system vulnerability to identified
threats Prioritizes risk reduction measures
Emergency Response Plan Incorporates findings of VA 8 core elements
ERP: 8 Core Universal Elements
System Specific Information
PWS Roles and Responsibilities
Communication Procedures
Personnel Safety
Identification of Alternate Water Sources
Replacement Equipment/Chemical Supplies
Property Protection
Water Sampling and Monitoring
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Emergency Preparedness Requirements
Development Of Regulation
2) Would mandating the ideal achieve the objective? Not necessarily….. The process of planning is as important as, if
not more important than, a plan Must establish relationships with response
partners
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Emergency Preparedness Requirements
Development Of Regulation
3) Adopt a tiered approach Systems serving a larger population
(greater than 1,000) will perform a full ERP and VA
Systems serving a smaller population (less than a 1,000) will perform the “Priority Measures Plan”
Priority Measures Plan
System Specific Information
PWS Roles and Responsibilities
Communication Procedures
Personnel Safety
Identification of Alternate Water Sources
Replacement Equipment/Chemical Supplies
Property Protection
Water Sampling and Monitoring
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Emergency Preparedness RequirementsPRIORITY MEASURES
• Identify alternate drinking water source(s) for both a short term (hours to days) and long term outage (weeks to months)
• Designate a method for distributing drinking water from the alternate source
• Generate an Emergency Contact List which shall be updated regularly and placed at key locations throughout the facility
• Establish procedures for notifying users, related agencies, and media contacts of the condition of water quality, water availability, and how to obtain water from the alternate source
• Familiarize and train system personnel with regard to these measures
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Emergency Preparedness Requirements
Who is subject to the proposed regulation?
Community water systems (CWS) Non-transient, non-community water
systems (NTNCWS) Transient non-community water systems
(TNC) serving 1,000 persons or more only
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Emergency Preparedness Requirements
What are the requirements?
CWS & NTNCWS serving ≥ 1,000 persons shall:
1) Conduct a security Vulnerability Assessment
2) Complete an Emergency Response Plan
3) Complete a thorough update of the Emergency Response Plan on a biennial basis
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Emergency Preparedness Requirements
What are the requirements?
CWS & NTNCWS serving ≤ 999 persons & TNC serving ≥ 1,000 persons
1) Complete the Priority Measures plan
2) Complete a thorough update of the Priority Measures plan on a biennial basis
TNC systems may elect to shut down in the event of an emergency, and therefore are not required to designate an alternate water supply or establish a backup power plan
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Resources
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Resources
FREE Water ISAC Pro Trial Subscription -- $500 value
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Summary
Requirement to report changes in contact information to the Program
Emergency Contact Lists & Communication Procedures
Proposed Emergency Preparedness Regulation