Contingency Plan Rule Changes December 5 2017 Dave

Contingency Plan Rule Changes December 5, 2017 Dave Riley Chad Wenger

Photo by Ohio EPA

Contingency Plan Rule Changes • Each community water system and wholesale system must prepare and maintain a contingency plan • The plan is a document or group of documents designed to ensure the delivery of safe drinking water at all times • When routine methods of delivery or treatment are compromised, the plan shall provide for the protection of public health. (notification, provision of alternative water and restoration of services)

Contingency Plan Rule Changes • When routine methods of delivery or treatment are compromised the plan shall provide for the protection of public health. (notification, provision of alternative water and restoration of services)

Two St. Louis plants flooding during a 500 -year weather event in December 2015. Photo by Treatment Plant Operator Magazine.

Contingency Plan Rule Changes • Location of the copies of the contingency plan ‒ An accessible and secure location at the water treatment plant ‒ Public water system administrators office, if applicable ‒ Systems with a population >250 must supply a copy to the County emergency management agency ‒ A copy must be provided to Ohio EPA within 5 days upon request

Contingency Plan Rule Changes • Contents of contingency plan – Map (detailed locations for each valve, well field, intakes and emergency connections) – Statement of amounts budgeted for emergency use along with a statement of who can authorize expenditures. A PWS shall ensure they have funds available and immediately accessible for emergency use – Most likely circumstances that will affect the PWS

Contingency Plan Rule Changes • Procedures to be followed and actions necessary to maintain or restore service. Procedures must address response and recovery activities (sampling plans, treatment options, notifications to the public and government agencies) • Plan must include protocols to identify appropriate and accessible sampling points and a description of how to select a sample point

Photo by Kyle Robertson, Columbus Dispatch

Contingency Plan Rule Changes • At a minimum the plan shall address: – Short term power failure (<2 hours) – Extended power failure (2 hours or more) – Pump or motor failure – Loss of water from a well or other water source – Line breaks that affect the routine delivery or treatment of water – Natural disasters – Unplanned absence of operator – Contamination of source water – Exceedance of a MCL or an action level – Violation of a treatment technique

Water main break in downtown Columbus, January 2014. Photo by Channel 10 WBNS

Contingency Plan Rule Changes • Systems using automation – shall include plans to manually operate the public water system • Exercise these plans to the extent possible and ensure different sections of the plan are exercised each month • Document exercises in operation and maintenance records

Contingency Plan Rule Changes • Auxiliary power – shall include plans to operate on auxiliary power in the event of a loss of power • Portion of the plan shall be exercised monthly in a way to not jeopardize the system • Document in operation and maintenance records

Contingency Plan Rule Changes • Provision to provide water from an alternate source including: – The process that will be used to obtain and transport water from the alternate source – Three or more possible source alternatives – Description of the source which may include interconnection and a method of disinfection – Sources shall be able to supply water of sufficient quality and quantity to support the drinking water needs of 1 gallon person per day

Contingency Plan Rule Changes • A description of the process for providing water within 24 hours of an incident • List of water users with critical needs for continuous supply of water. The list shall include contact information that ensures a representative can be contacted at any time of day • A description of the process used to determine the list • A list of consecutive systems with contact information • Identification of method and timing of notification to Ohio EPA, local health departments and local EMAs

Contingency Plan Rule Changes • Maintain records documenting time and method of notification • If depressurization due to physical disruption or operational disruption has occurred the procedure that will be used to return the system to normal service

Contingency Plan Rule Changes • 24 hour phone numbers for Ohio EPA DDAGW and the ER hotline • Police • Fire • County EMA Director • Water supply personnel • Administrative personnel • Contractors

Contingency Plan Rule Changes • • Electrical power supplier Electricians Well drilling or pump service contractors Equipment suppliers Certified laboratories Local health departments Individuals who are able to authorize spending

City of Logan Water Main Break, April 2017. Photo by Russell Flagg, Ohio EPA.

Contingency Plan Rule Changes • Exercising the contingency plan – Conduct annual exercises of one or more of the circumstances identified in the plan. The exercise can be discussion-based, tabletop or live. Exercises do not need to occur outside of normal business operations. Each circumstance shall be included in an exercise at least once every five years – Community PWS shall consult with the County EMA regarding participation in hazardous spill exercises – Documentation shall include the topic, outcomes and a discussion of improvements necessary

Contingency Plan Rule Changes • Annual Revision of plan – Contact information shall be confirmed during the annual review – Copies of revised pages distributed to all holders of the plan – In the event the plan is deemed inadequate or incomplete by Ohio EPA the PWS shall revise the plan in accordance with a schedule acceptable to the Director

Contingency Plan Rule • If plan activated: – Follow the plan to the extent circumstances allow. – Notify Ohio EPA immediately. – Develop written after action report that assesses the effectiveness of the plan and any changes necessary. • Plans submitted to Ohio EPA are not public record • Update inventory information annually with phone numbers to ensure a response within 30 minutes

Contingency Plan Rule Changes • Implementation – Webinar developed for systems – Phone calls by Districts to ensure systems are aware of the new rules – Certification by systems that they are aware of the rules and have updated the contingency plan (associated with inventory forms in August)