SECTION V

PLANNING FOR THE FUTURE:
CONTINGENCY PLANS AND PLANS FOR SITING NEW WELLS

Introduction:

Subsection 1428(a)(5) of the Safe Drinking Water Act (SDWA) requires that state WHP plans include Contingency Plans:

"for the location and provision of alternate drinking water supplies for each public water system in the event of well or well field contamination..."

"When a natural disaster strikes, an unprepared water system is no more immune from destruction than any other structure. However, preventive measures can be taken, both economically and structurally, to ensure that a water system minimizes the amount of damage inflicted by any future tornadoes, hurricanes, fires, floods, earthquakes, and other natural disasters. Returning a water system to normal operation is essential to protecting public health and aiding the community's recovery process.

Since natural disasters usually offer little or no advance warning, it is important that water systems be prepared for nature's destructive forces. And though some regions of the country are more prone to certain types of natural disasters, no place on earth is disaster-free, so water officials everywhere should expect the unexpected.

For this reason alone, water systems should develop an emergency response plan to prepare for natural disasters, limit damage, and expedite recovery. Many small water facilities simply do not have the resources to take such elaborate preventive measures. There are, however, agencies at the local, State, and federal levels that can help water facilities of all sizes prepare for and recover from natural disasters.

There are several measures all water systems can take to lessen the impact of disaster. Some of the more important measures include having an emergency preparedness guide for your utility and your customers and making sure you have adequate financial reserves for general repairs and equipment replacement. Systems should also make sure there are plenty of repair parts available and that all emergency back-up equipment functions properly.

More specifically, ...water utilities should:

Keeping good records is one of the most important emergency preparations a water system can make. This will help the system's efforts in assessing damage and evaluating restoration costs. Videos and photographs are excellent tools to inventory assets before a disaster and to document damage afterward.

Depending on where your water system is located and what type of disaster it's likely to face, the system will have to customize its emergency management plan to meet the system's most immediate needs before and after a natural disaster. Organizations such as the Federal Emergency Management Association (FEMA) and the American Water Works Association have created emergency management manuals for designing emergency preparedness plans for water systems." The National Rural Water Association has also created an emergency management manual. See Appendix C for contact information.

CONTINGENCY PLANNING:

Contingency Plans address problems that PWSs may need to overcome in the event of water supply shortages or a contamination incident that impacts the system's ability to supply an adequate quantity of safe drinking water to the public. Contingency Plans should focus on the identification of problems that may arise if protective and preventative measures fail, and solutions to resolve those potential problems. Contingency Plans help communities answer questions such as:

WHP Contingency Planning Team:

Establishment of a planning team to develop the Contingency Plan is recommended. When forming the WHP Contingency Planning Team it is essential to include representatives from the various local agencies and community interests that would have a role to play in the case of an emergency. The following officials or representatives should be represented on the Planning Team:

Although the size of the team will vary with the size and characteristics of the community, the basic goal should be to provide for broad community participation in the planning process. The team should pick a leader (e.g. Emergency Coordinator) who will be capable of contacting, mobilizing and coordinating the team's work during an emergency situation. When the team defines potential 'problem' scenarios, specific duties will be more clearly defined. It is important to assign responsibility for each potential task to an individual or group leader during the planning process, rather than waiting until an emergency situation arises.

Local contingency planning has been required since 1986 under the Federal Emergency Planning and Community Right-to-Know Act (SARA Title III). Title III establishes a network of County Emergency Management Coordinators and Local Emergency Planning Committees charged with planning response to emergency releases of hazardous chemicals.

Wyoming Emergency Management Agency (WEMA):

The Wyoming Emergency Management Agency is responsible for the coordination and implementation of the state Emergency Management Program, including the state's Event Management Plan. During an emergency or disaster, WEMA coordinates state and federal resources to support local jurisdictions.

County Emergency Management Coordinators (CEMC):

The County Emergency Management Coordinator (CEMC) reports to the County Commission and is directly responsible for the administration and operation of the county emergency management program, including the County Emergency Operations Plan. The coordinator is an excellent resource and will be an asset to any contingency planning committee. The name and phone number of the coordinator for each county is contained in Appendix M.

Local Emergency Planning Committee (LEPC):

The Local Emergency Planning Committee (LEPC) has two primary roles: 1) to prepare a local hazardous materials response plan, and; 2) to manage the paperwork flow of submissions (under SARA Title III) from industry, and their disclosure in response to requests.

Transportation Community Awareness and Emergency Response (TRANSCAER):

TRANSCAER's "Regional Approach" program creates partnerships among manufacturers, distributors and transporters of hazardous materials, and state and local community emergency planning and response groups. TRANSCAER provides resources for establishing emergency response plans and training and can help local emergency response organizations draft and test emergency plans pertaining to hazardous materials transportation. TRANSCAER is sponsored by the Association of American Railroads (Washington, D.C.), Chemical Manufacturers Association, National Association of Chemical Distributors (Arlington, VA), National Tank Truck Carriers Inc. (Alexandria, VA), American Petroleum Institute (Washington, D.C.), Hazardous Materials Advisory Council (Washington, D.C.), American Trucking Associations (Alexandria, VA), The Chlorine Institute Inc. (Washington, D.C.) And National Propane Gas Association (Lisle, IL).

Oil and Hazardous Substances Pollution Contingency Plan:

The State of Wyoming has had its Oil and Hazardous Substances Pollution Contingency Plan in place since 1989. The purpose of the plan is to help ensure coordination of timely, effective response activities by various state agencies and other organizations to releases of oil or hazardous substances which enter, or threaten to enter, waters of the state. The plan details the responsibilities that each involved state and federal agency will have during an environmental emergency incident.

Both the CEMC and LEPC response plans may provide a starting point for WHP contingency planning. Operation and Maintenance (O&M) manuals designed for existing systems should also contain information on contingency planning.

In addition to forming a Contingency Planning Team, an "Emergency Control Center" should be designated. The center can be as simple as a desk drawer dedicated to emergency response; the idea is to make sure that all of the information needed to implement the Contingency Plan is organized and accessible, and that all team members are aware of where the Contingency Plan is located. The center should be equipped with copies of the team roster and the names and phone numbers of other important contacts, and all pertinent information regarding the water supply sources, appurtenances, distribution system, and storage system. A list of contractors capable of repairing the various components of the system and of suppliers who carry power generators and any other equipment that might be necessary for repairs or emergency system operation should also be compiled and kept at the "Emergency Control Center". If available, a cellular phone or radio could be kept at this location to provide a means of communication in case of a phone service outage.

Appendix N (Form V-1) contains a model form that should be used to identify and record the capacity and demand (i.e. use) for each well included within the WHP Plan. This information can usually be obtained from PWS, City Engineer or town files and/or from consultant reports such as water supply master plans. This type of inventory will assist the PWS in determining if an emergency situation likely will arise in the event that one or more drinking water sources is lost because of contamination. Schematic (construction) diagrams of the water supply system are valuable for identifying the locations of the system components and evaluating alternatives for treatment, storage, distribution, etc. in the event of an emergency. Having this information readily accessible will expedite decision making during an emergency.

Appendix O (Form V-2) provides a general format for identifying and keeping track of personnel responsible for coordinating activities during an emergency or disaster and the state and federal agencies that must be contacted if a hazardous substance release occurs.

Identifying and Ranking Potential Problems:

Each PWS should decide for itself what it will consider a threat or contingency that needs to be addressed in the Contingency Plan. Regardless of how the PWS sets its priorities, it is useful to think of determining the appropriate contingencies as a screening process. The WHP Contingency Planning Team might first identify a variety of contingencies and then screen the contingencies to assess their importance.

Table V-1 on the following page presents a format that was adapted from EPA (1990) to be used for listing and ranking potential threats to drinking water supplies by assigning estimates for both probability and severity. Those threats with a high probability are typically more likely to occur, while those with high severity will likely have a greater adverse effect on the water system. Past experiences and the experience of other local PWSs should be considered when assessing each threat.

Whatever method or format is selected, the screening of a large set of potential contingencies should yield a smaller set of "primary" contingencies. These threats can then receive the most urgent attention in the planning process. Once the WHP Contingency Planning Team has identified the "primary" set of supply disruption contingencies, these threats should be summarized in a way that is useful in designing appropriate response actions; Form V-3 (Appendix P) is suggested as a basis to accomplish this.

TABLE V-1
EXAMPLE OF EMERGENCY PROBABILITY AND SEVERITY CHART

TYPE OF EMERGENCY PROBABILITY
(10-High - 1-Low)
SEVERITY
(10-High - 1-Low)
REMARKS
Natural


Drought


Flood


Ice & Snow Storm


Wind


Earthquake


Fire


Man-Made


Spill/Chemical
Contamination



Sabotage


Power Outage


Operator Error


Equipment Failure


Explosion


Vandalism


One of the most effective ways of identifying threats for planning purposes is to describe potential water supply disruption scenarios that summarize situations in a brief, narrative form, as illustrated in the following examples:

Scenario 1 - Transmission Disruption Due to Landslide: Water from Well No. 2 to the town's water storage tanks is carried in a transmission line that is located in an area prone to landslides. In the autumn of 1994 a landslide occurred and ruptured the transmission pipeline. As a result, the town was left with a supply of approximately 15 gpm from its backup well.

Response: Town officials immediately implemented water rationing; the rationing order is advertised at Post Office and by word of mouth. They also immediately contacted the engineer who had been working on another part of the system. Repair work was completed the following day. The seriousness with which the residents of Elk Mountain responded to the rationing order allowed enough storage to remain in the tanks to provide emergency fire flow, which luckily was not needed during the event.

Scenario 2 - Chemical Spill: With the principal land use in the area being industrial, chemicals are potential threats to the Pleasantville drinking water supply. A release of these chemicals into the groundwater could gradually lead to a contamination problem. Storage and transportation of these substances poses an additional risk to groundwater, including the possibility of a sudden, accidental release to the drinking water supply.

Response: In the case of a sudden release of chemicals in Zones 1, 2 or 3 of the WHPA, Pleasantville officials will immediately contact the DEQ and the National Response Center. The wells closest (down gradient) to the spill will be isolated from the rest of the water supply system. Rationing will be imposed to limit the amount of water that is drawn toward the well field. The town will monitor water from the wells down gradient from the spill. Water from the remaining wells will be utilized until contaminants appear in the monitored wells. If contaminants appear in the monitored wells at levels exceeding EPA drinking water standards or guidelines the remaining wells in the field will also be removed from use. As soon as possible after the spill, bottled water suppliers, neighboring towns, owners of irrigation wells, and owners of water trucks will be contacted to determine the availability of an alternative water supply. If abandonment of the well field becomes necessary, Pleasantville will drill a new water supply well as soon as possible at the base of Windy Ridge.

Scenario 3 - Traffic Accident & Spill: Highway 123 passes within 200 feet of Windy City's Well No. 3. The transportation of hazardous substances along this major north-south route poses the risk of major spills which could threaten the safety of the drinking water supply. In addition, several gas stations built to serve highway traffic could contribute a well-defined set of petroleum derivatives to local groundwater, either through gradual leakage of the storage tanks or a sudden rupture or spill.

Response: In the case of a spill in Zone 1 of the WHPA, pumping at the well would cease. Windy City Well No. 3 is the sole source of drinking water for the city; however, older municipal wells supply the high school (Well No. 2) and the State Highway Patrol station and Veterans' Memorial Hospital (Well No. 1). While no longer connected to the distribution grid, these wells could be used to supply the town in an emergency situation. The city engineer estimates that the wells could be connected to the distribution grid within four working days. Until the wells are connected to the system, residents would have to haul water from one of the existing wells.

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 different Zones of the WHPA, well collapse, line break, or power loss) to allow development of different response approaches.

Considerations for Contingency Plan Responses:

Responses to water shortages will necessarily vary depending on the cause of water supply disruption. Short-term solutions may involve instructing users to boil water before use, trucking water from another source, or conservation during minor system repairs. Regardless of the type of response, the users of the water system should be notified immediately of the problem and of any treatment, rationing, or conservation measures to be implemented. Public meetings, the local newspaper(s), and local radio station can all be utilized for this purpose. A form that may be modified for use as a local press release is provided in Table V-2.

In the event that a source of drinking water is lost because of contamination, a new source of water may have to be developed, either within the same aquifer, or another aquifer if possible. If development of another aquifer is not possible, the remaining alternative may be to develop a new well in the contaminated aquifer (preferably in an area not subject to future contamination) or provide for treatment of the water supply to remove contaminants.

TABLE V-2
EXAMPLE PRESS RELEASE

(For distribution to television, radio and newspaper media.)

The following information regarding (1) protection of the Pleasantville well field, (2) detection of a substance in the Pleasantville water supply; or (3) the current water shortage problem:

It is vital that all residents served by the Pleasantville water supply system observe the following water use restrictions until further notice:

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 _______________________________________ at this phone number: _____________________________.

A press conference is scheduled for _______________________________________ to be held at ________________________________________.

News updates will be provided as additional information becomes available. Attached please find a copy of an information sheet which provides details concerning the physical plans, organization structure, and function of the Pleasantville water system.

Time:

Date:

Signed:

Title:

Long-term response usually involves testing (e.g. sampling) the PWS (in the case of a contamination event), rationing uncontaminated water, treating contaminated drinking water, disinfecting the water system or taking other appropriate repair or clean-up actions.

Both the Wyoming Association of Rural Water Systems and WEMA can be contacted to learn of portable water purification units which may be available for use in emergency situations; frequent sampling and monitoring of the water may be necessary to ensure that the water supply remains safe for drinking. More detailed discussions of various treatment alternatives can be found within several of the reference aids listed in Appendix C.

Potential State and Federal Funding for Emergency Drinking Water Supplies:

Water systems must be financially prepared in the wake of a natural disaster to ensure that service will be restored quickly and safely. Some small water utilities, especially those without disaster insurance, emergency reserves, or financial reimbursement from disaster-relief funds, may struggle to restore service following a natural disaster.

There are a variety of financial reimbursement opportunities available to disaster-stricken water systems. The majority of this financial assistance comes in the form of loans, although sometimes grants are available, and most list specific requirements that applicants must meet before qualifying for assistance. All or a portion of the costs resulting from a disaster may be eligible for local, state, and/or federal disaster-relief funding, but only if those costs are clearly identified by the applicant.

Factors such as whether a system is public or private, whether it is insured, the system's size, and whether an official federal disaster has been declared can all determine the type of financial assistance and the amount of money that can be provided.

Since financial reimbursement from disaster relief funds can take up to a year to receive, water systems should maintain repair and replacement funds that can be tapped after an emergency. Although sometimes difficult, reserving funds should be an integral part of every water system's emergency preparedness effort.

As a general rule, emergency operations, including financial assistance, will begin at the level of government most appropriate to provide an effective response. At the local level, some counties, particularly in disaster-prone areas, have established emergency reserve funds for homeowners, small businesses, and small government utilities.

According to FEMA, much of what the federal government provides to small water/wastewater facilities are low-interest loans through the Small Business Administration and low-interest loans and grants through the U.S. Department of Agriculture's Rural Utilities Service (RUS). These funds can be used to repair and replace damaged property not covered by insurance.

For the most part, water systems become eligible for federal assistance if they are located in a county or area that has been declared a federal disaster area; suffer sufficient property damage or loss; and do not have sufficient income, insurance, or other cash resources readily available to cover the cost of damages. Even with reserve funds, systems may not be able to cover all expenses."

The cost for the purchase and delivery of short-term and long-term water supplies must be determined on a case-by-case basis. Generally, the burden of the cost of clean up following a contamination incident rests with the person or persons responsible (i.e. responsible party') for the incident. However, there may be no identifiable responsible party, or none with sufficient financial resources to carry the burden or meet the immediately incurred costs.

In response to the possibility of such situations, in 1989 the Governor of Wyoming established provisions which allow the Governor's Contingency Fund to be utilized for containment, cleanup, and disposal of substances posing an eminent threat to the heath, safety or welfare of humans, wildlife and/or waters of the state (including groundwater). These funds are available only when immediate action is required or the responsible party is unknown. The funding must be requested from the Governor by the WDEQ Director.

Limited federal funding may be available through the Pollution Revolving Fund, administered by the U.S. Coast Guard, for the reimbursement of state and federal costs related to the containment, removal, mitigation, and disposal of oil releases. In addition, EPA may provide limited funds to ensure timely initiation of containment action when use of the Pollution Revolving Fund is not authorized. Requests for EPA funds must come from the Governor. Additional information is available in the Wyoming Oil and Hazardous Substances Pollution Contingency Plan (1989) and Section 311(k) of the Clean Water Act.

As a general rule, emergency operations, including financial assistance, will begin at the level of government most appropriate to provide an effective response. At the local level, some counties, particularly in disaster-prone areas, have established emergency reserve funds for homeowners, small businesses, and small government utilities.

According to FEMA, much of what the federal government provides to small water/wastewater facilities are low-interest loans through the Small Business Administration and low-interest loans and grants through the U.S. Department of Agriculture's Rural Utilities Service (RUS). These funds can be used to repair and replace damaged property not covered by insurance.

For the most part, water systems become eligible for federal assistance if they are located in a county or area that has been declared a federal disaster area; suffer sufficient property damage or loss; and do not have sufficient income, insurance, or other cash resources readily available to cover the cost of damages. Even with reserve funds, systems may not be able to cover all expenses.

Where to Go For Help:

"In the event of an emergency, there are several emergency assistance organizations and agencies that are able to help your water system prepare for, respond to, and recover from a natural disaster. Many of these organizations will appear on the scene following a natural disaster.

Some of the services these organizations provide include clearing debris; restoring power and utilities; providing food, shelter, and clothing; offering technical assistance; providing emergency -preparedness courses and literature; and providing emergency loans and grants following a natural disaster."

CONTENT AND ORGANIZATION OF THE CONTINGENCY PLAN:

In formulating a Contingency Plan, the WHP Management Committee, or its designate, must address and include the following in its WHP Plan:

PLANNING FOR NEW WELLS:

Introduction:

Subsection 1428(a)(6) of the SDWA specifies that the State WHP plan shall require that:

"consideration be given to all potential sources of contamination within the expected wellhead area of a new groundwater source (i.e., well, spring, or tunnel) which serves as a public water supply system..."

Planning for New Groundwater Based PWSs:

Because more planning is possible for a new groundwater source than is feasible for existing wells, the WHP Management Committee may find it beneficial to combine planning for the siting of new wells with other community planning and development activities. Development of new groundwater sources of drinking water should conform with overall community development plans. For example, assessing growth potential or the direction of future expansion into anticipated WHPAs should be factored into the new wellsite selection process. Communities in high growth areas may examine land-use patterns and elect to direct industrial development or other potential sources of contamination to areas that do not pose a threat to the water supply. Where communities determine that land-use controls alone are insufficient or inappropriate, they may wish to adopt other management strategies (see Section IV) to protect groundwater and drinking water quality. For potential wellhead areas identified as particularly sensitive' (see Section III) to contamination, communities may decide to restrict certain activities that pose a high risk of contamination.

Taking steps before a problem arises has the added advantage of avoiding disruptions to existing land uses and potential legal challenges. As another example of this proactive approach, major undeveloped aquifer areas may be designated and managed as potential WHPAs if they are logical sites for future drinking water sources. PWSs, local planning authorities, and zoning boards should work together to identify potential WHPAs for emergency or future uses. Potential contaminant sources that lie within these potential WHPAs may then be identified and managed in a manner similar to that applied to potential sources that lie within existing WHPAs.

Public participation is an essential component of water supply planning. The expansion of WHPAs due to increasing demand or the creation of additional WHPAs may be of concern to businesses and residents located within WHPAs. To foster responsible water supply practices at the local level, public hearings on water development plans and source management approaches are strongly encouraged. A public forum for long-term water supply planning issues may be a natural extension of the duties of a community's WHP Management Committee.

Existing Regulatory Requirements for Siting New and Modified Public Water Supply Wells:

Chapter XII of WDEQ's Water Quality Division Rules and Regulations establishes siting requirements (Section 8: General Design Considerations) and general considerations (Section 9: Source Development) for locating new (and modifying existing) public water supply wells serving 20 or more connections (see Glossary: PWS - DEQ) in relation to most potential sources of pollution. Specifically:

Section 8(b)(i) states:

"...[Water] Treatment facilities shall be located such that no sources of pollution may affect the quality of the water supply or treatment system. The facilities shall not be located within 500 feet of landfills, garbage dumps, or wastewater treatment systems".

Section 9(b)(i)(B) states:

"....Every well shall be located further from any sources of pollution listed below..."

Section 9(b)(i)(B)(IV) states:

"For wastewaters other than domestic wastewater, the isolation distance required shall be determined by a hydrogeologic study, in accordance with the requirements of Section 15 of Chapter III Water Quality Rules and Regulations".

In order to determine and establish the required isolation distances from the well:

Additionally, Section 6(c)(v)(A)(III) (Engineering Design Report) of Chapter XII states that 'sources of water supply shall be described to include':

"Sources of possible contamination around the well and in any known recharge areas, including location of any waste site, industrial facilities and wastewater disposal areas".

Progressing to a Final WHP Plan:

Using the WHPA delineation and Source Inventory list developed for permitting new and modified public water supply wells, the WHP Management Committee should undertake the remaining steps to complete the WHP plan for the new/modified water supply source. These remaining steps include: