NMED's Drinking Water Emergency Response Plan and other Security Issues

1. NMED's Drinking Water Emergency Response Plan and other Security Issues

2. Introduction • Jerry Lewis • NMED Drinking Water Bureau • Albuquerque Office • The purpose of this training is to familiarize you with the DWB’s Drinking Water Emergency Response Plan and other DWB security initiatives.

3. Topics of Discussion • NMED’s drinking water emergency communication protocol • DWB’s emergency response plan • The emergency test kit program • Site characterization during a potential water contamination incident • Other NMED/DWB outreach activities • NMED Security Program and Contacts • Reference materials

4. NMED/DWB’s Drinking Water Emergency Communication Protocol • Once the incident is confirmed, the system must fill out the reporting form and make 3 phone calls: • Local law enforcement/911 • NM Emergency Operations Center (505) 476-9635 (DO NOT DELAY THIS CALL TO GET LAT./LONG. INFO.). Can be submitted later. • Local Drinking Water Bureau District Office • If there are signs of terrorism, call the FBI (505) 889-1300.

5. Emergency Communication Protocol (Cont’d) • The NMEOC will immediately call the following agencies: • NM Environment Dept. On-Call Emergency Contact • NM Dept. of Health On-Duty EOCR • NM State police • FBI • Governor’s Office of Homeland Security • City/County Emergency Manager • EPA Region 6 Emergency Response Center • With 3 phone calls, all interested agencies are alerted.

6. Emergency Communication Protocol (Cont’d) • Designed for all communications to go through the NMEOC • Chain of Communication • Agencies outside of NMED contact the NMEOC • NMEOC contacts the DWB Security Coordinator for the appropriate DWB District • DWB Security Coordinator contacts DWB water system oversight person • Oversight person is the liaison with the water system • Reverse Chain of Communication • Water system to DWB oversight person • Oversight person to District Security Coordinator (DSC) • DSC to NMEOC • NMEOC to outside agency

7. Emergency Communication Protocol (Cont’d) • Chain of Communication • Limits contact with the water system • Water system busy responding to the incident • This procedure also keeps all players in the information loop • Exception to this protocol • Law enforcement • DSC will give NMEOC the water system contact info. for forwarding to local law enforcement (LLE). • Water systems must train their personnel on these procedures.

8. NMED/DWB’s Drinking Water Emergency Response Plan • Designed to help the water system and DWB security personnel/oversight staff work together efficiently to respond appropriately. • It consists of: • A cover page and Introduction • A Table of Contents of the different types of emergencies • The 6 chapters • Appendices • Emergency Communications Protocol • Site Characterization • ERP Resources and tools • Needed Sampling Equipment

9. NMED/DWBs ERP (Cont’d) • Chapters 1 – 4 are divided into 6 sections • Initial actions of NMED staff when first notified of incident • Responsibilities of the DWB District Security Coordinator (DSC) • Responsibilities of the DWB oversight staff • Water system responsibilities Public Notification • Emergency response evaluation and ERP update. • Chapters 5 and 6 deal with acute fecal coliform and acute nitrate violations

10. NMED/DWB’s ERP (Cont’d) • Chapters • Chapter 1. Potential or Known Water Contamination Event or Threat; • Chapter 2. Attack or Threat Against Water System Facilities, Infrastructure, Personnel or Administrative Resources; • Chapter 3. Cyber Attack Against Computer or Software Assets or System Facilities Through the Internet or Phone Lines);

11. NMED/DWB’s ERP (Cont’d) • Chapters Cont’d • Chapter 4. Natural Disasters or Accidents; • Chapter 5. Acute Fecal Coliform Contamination • Chapter 6. Acute Nitrate Contamination

12. NMED/DWBs ERP (Cont’d) • Initial Actions by NMED (potential contamination incident) include • Log-in of original notification and subsequent contacts • Gathering of critical information • Detailed Information will be needed as other agencies get involved and the emergency response progresses. • Notification of DWB Security coordinator in Santa Fe.

13. NMED/DWBs ERP (Cont’d) • Responsibilities of the DWB District Security Coordinator (potential contamination) include: • Takes the lead for NMED/DWB • Establishes chain of communication with NMEOC • Includes giving NMEOC: DSC, DWB oversight and water system contact information • Maintains contact with other agencies through NMEOC • Oversee the “Site Characterization” process for NMED • Evaluates results of initial sampling (airborne radiation, conductivity, pH, cyanide, chlorine residuals and radiation in the water) • Assists in developing a standard laboratory sampling schedule (input from EPA Region 6 • Develop system assistance needs • Assists in public notification • Notification of nearby systems

14. NMED/DWBs ERP (Cont’d) • Responsibilities of the DWB Oversight Staff Person • Liaison with water system • All requests for information and water system responses go through the oversight person, DSC and NMEOC. • Provide on-site assistance with sampling, site characterization, damage assessment, etc. if requested • Laboratory contact if standard lab samples will be collected.

15. NMED/DWBs ERP (Cont’d) • Responsibilities of the Water System (Potential contamination) • Water system evaluates the threat • Is the threat possible? • Is the threat credible? • Has the incident been confirmed? • Once the incident is confirmed, the water system activates its ERP. (if no ERP, NMED will assist) • The system makes the 3 initial phone calls that activates statewide emergency response (4, if terrorism is indicated). • Awareness of the potential presence of any type of contaminant (WMD, nerve agents, hazardous substances, etc.

16. NMED/DWBs ERP (Cont’d) • Protection of Evidence During Damage Assessment and site inspection • Site Characterization • Isolate potentially contaminated sections of the distribution system/storage tanks, wells, etc. from the rest of the system. • Turning valves • Flushing lines, storage tanks, etc. (Keep in mind that flushing water containing hazardous substances may be illegal). • Identify additional/secondary sites of potential water contamination. • Collection of chlorine residuals • Collection of total coliform samples • Boost the chlorine residual anywhere contamination may have spread.

17. NMED/DWBs ERP (Cont’d) • Public Notification (Potential Contamination Incident) • When to issue public notification • If there is a realistic chance that contaminated water has entered the distribution system (Tier 1 public notification) • If the contaminant is not known, do not include health effects language. • If it is unknown whether contaminated water has entered the distribution system or if there is a possibility that the distribution system has been contaminated (designed on case by case basis) • This message should briefly describe the incident, what steps are being taken to contain potential contamination, what contaminants are being looked for and how the system will keep the community updated. • If there is no possibility of distribution system contamination, public notification is not necessary.

18. NMED/DWBs ERP (Cont’d) • General types of public notification for potential contamination • Precautionary Boil Advisory – when there may be fecal bacteriological contamination in the system that would be killed by boiling the water; • Boil Advisory – When there is fecal bacteriological contamination that would be killed by boiling the water; • Do Not Drink Order – When there has been contamination, the contaminant is known and there is no risk of dermal or inhalation exposure; • Do Not Use Order – When there is contamination, there may be a risk of dermal or inhalation exposure or the contaminant is not known; • Notification of Incident – When it is unknown if the system has been contaminated or not.

19. Chapter 5. Acute E-Coli Contamination • 4 ways an acute bacti violation occurs • Chronological listing of events, requirements, etc. • Appendix 5A • Technical assistance checklist for finding the cause of an e-coli violation • Appendix 5B • “Boil Advisory” supplemental information

20. Chapter 5 (Cont’d) • Four ways an acute bacti violation occurs: • “Routine” total coliform sample is total coliform positive and 1 “Repeat” sample is e-coli (fecal coliform) positive; • “Routine” total coliform sample is e-coli (fecal) positive and 1 or more “Repeat” samples are total coliform positive; • The water system declares an “acute violation”. In this event, all the required “Repeat” samples must still be collected. • The “Routine” total colifom sample is e-coli (fecal coliform) positive and the system fails to collect all required “Repeat” samples correctly.

21. Chapter 5 (Cont’d) • Chronological listing of events (highlights only) • Notification of system or NMED/DWB • Alerting of NM Department of Health (NMDOH) • Co-ordination of activities, • Decision re “Precautionary Boil Advisory” (BA) or “BA” and /or press release. Discuss pertinent issues. • Possibility of waterborne disease outbreak • System is sent (e-mail/fax) a blank “Boil Advisory” for their use. • System is advised how to execute a “Boil Advisory” (see Appendix 5B). • System must maintain contact with NMED/DWB on a daily basis • Required site inspection by DWB oversight person • Go over water system’s public notification requirements • If possible, determine cause of contamination (see Appendix 5A), • Discuss pertinent issues.

22. Chronological Listing of Events (Cont’d) • Public Water System Public Notice Requirements • Must be done within 24 hours of notification • Must reach all residential, non-transient and transient users of the drinking water • One or more of the following forms of delivery: • Appropriate broadcast media (radio or TV) • Posting of the notice in conspicuous locations (schools, work places, restaurants) • Hand delivery of notice to all customers • Another delivery method approved in writing by NMED/DWB. • NMED/DWB with input from system will decide upon required public notice delivery

23. Chronological listing of events (Cont’d) • NMED/DWB oversight person sends violation letter to system with public notification requirements. • Also includes steps system can take to clean out system and return to compliance. • Shock chlorination of system • Rural Water technical assistance • Collection of a clean total coliform sample (special) from distribution system on 2 consecutive days • DWB works with system to insure that all requirements are met and that the drinking water can be declared “safe to drink” • When all requirements are met, NMED consults with NMDOH. If agreed upon: • NMED Press Release and “Boil Advisory” is rescinded • Second press release rescinding the “Boil Advisory” • Water system is called to rescind public notification and “Boil Advisory”.

24. Chronological listing of events • Inform water system of requirement to collect 5 “routine” samples the month following a total coliform positive • Possible order/requirement from NMED/DWB that the water system must install continuous, automatic disinfection of all water produced. • NMED should require this in certain situations • The proposed “Groundwater Rule” may require this.

25. Chapter 6. Acute Nitrate Contamination (highlights only) • Quarterly nitrate sampling • A ground water public water system goes on quarterly sampling when a routine annual sample is greater than or equal to ½ the MCL. • A surface water system that has been granted annual sampling goes on quarterly sampling when a routine annual sample is greater than or equal to ½ the MCL.

26. Chapter 6. (Cont’d) • Chronological Listing of events • If a “Routine” annual or quarterly nitrate/nitrite sample exceeds the MCL of 10 mg/L, the system must collect a “confirmation” sample within 24 hours of notification. • If a “Routine” nitrite sample exceeds the MCL pf 1 mg/L, the system must collect a “confirmation” sample within 24 hours of notification. • If a “confirmation” sample cannot be collected within 24 hours of notification, the water system must perform the required public notification within 24 hours of notification of the exceedance. • These systems must collect a “confirmation” sample within 2 weeks. • The results of the initial sample and the confirmation sample are averaged to calculate compliance.

27. Chronological listing of events (Cont’d) • Once the violation is confirmed, the DWB must co-ordinate with NMDOH from the Santa Fe office. • Public notification requirements (similar to an acute bacti event). • Must be done within 24 hours of notification • Must reach all residential, non-transient and transient users of the drinking water • One or more of the following forms of delivery: • Appropriate broadcast media (radio or TV) • Posting of the notice in conspicuous locations (schools, work places, restaurants) • Hand delivery of notice to all customers • Another delivery method approved in writing by NMED/DWB. • NMED/DWB with input from system will decide upon required public notice delivery.

28. Chronological listing of events (Cont’d) • NMED/DWB sends an acute nitrate/nitrite or nitrite acute violation letter to the water system. • Formal notice of how and when to post public notification • Other information as appropriate • This public notification must remain posted as long as the violation persists. • If a community water system, all new billing units or new customers must get a copy of the PN as long as the violation persists. • A system with an acute nitrate violation must begin looking for a way to reduce nitrate/nitrite or nitrite levels below the MCL. There is no time limit, but NMED can and will set a deadline.

29. NMED DWB’s Emergency Test Kit Program • Recommended in EPA’s “Response Protocol Toolbox” • Designed to provide an emergency testing capability throughout New Mexico; • 149 test kits distributed throughout NM and in DWB field offices; • Tests for: airborne radiation, cyanide, pH, conductivity, chlorine residual and radiation in the water; • Only effective if system knows the historical levels of pH, conductivity, chlorine residual and cyanide. • Test Kits generally offered to systems serving >500 people. If your system is interested, call your local District office to see if a test kit is available. • Envisioned that Test kits and/or trained personnel will be available for sharing this testing capability in an emergency. • Call a larger or nearby water system that has a test kit for help in an emergency.

30. Site Characterization • Process to determine if hazardous material, WMD, etc. was brought into the site and identify it if possible. • Includes: • Radiation screening (airborne) • Initial site survey from outside the compound • Site inspection • Take care to preserve and protect possible evidence for criminal prosecution • Damage Assessment • Basic Rapid Field Testing (pH, conductivity, cyanide, chlorine residual and water screen for radiation) • Identify additional/secondary sites of potential water contamination. • Note: This investigation is done in stages. After each stage, the investigating crew reports its findings to the Incident commander, who then authorizes the next stage.

31. Site Characterization (Cont’d) • If someone has breached your security and entered a facility: • Any chemical, hazardous substance, WMD, bio-toxin, pathogen, etc. could have been brought into the site. • The site must be cleared for entry by a step process that reduces risk as the investigation progresses. • This is called “Site Characterization”. Generally used during a potential water contamination event. • As the investigation proceeds, risks are eliminated (radiation, evidence of hazardous material is scanned for, etc.).

32. Site Characterization (Cont’d) • Radiation Screening (Record all readings) • Collect a radiation background reading well away from the site (1 mile or more). • Take a counts per minute (CPM) reading just outside the site. If the reading is <3 times the background level, proceed with the screening. • Inside the compound, continue scanning until you are certain that there is no airborne radiation. • If a reading of 3X the background level is obtained, the “site characterization” is over. All Untrained and unprotected personnel must leave the site immediately and the NMED Emergency Response Team must be called. (505) 660-3107 (cell), (505) 827-9329 (office).

33. Site Characterization (Cont’d) • Initial Site survey from outside the compound • Complete while radiation screening is proceeding • Scan the area for evidence of what might have been brought into the site • Gas can • Container with residual material • Pumps or hoses • Written material • Evidence of hazardous material, WMD • Personal protective equipment used to protect perpetrator from hazardous material. • Any evidence found could help identify types of contaminants/agents to officially test for. This is very important and could cut sampling costs a great deal.

34. Site Characterization (Cont’d) • Site Inspection • If the radiation screen and the external initial site survey are negative, the incident commander can give the OK for the site inspection. Note: During the site inspection, it is very important to be aware of potential evidence and to not disturb it or corrupt it. No repairs, etc. until site is cleared by law enforcement. • Radiation screening inside compound is done first. • If clean, conduct site assessment; • Conduct damage assessment; • If there is a possibility of water contamination, run conductivity, cyanide, pH, chlorine residuals. Compare with historical readings • Scan water for radiation in the drinking water– (wet paper towel, dried and scanned with meter.).

35. Site Characterization (Site Inspection) Cont’d • Identify additional/secondary damage/potential water contamination sites within the water system. • If there is an additional intrusion/secondary damage site, conduct “Site characterization” wherever necessary. • Additional activities associated with the site inspection • Collection of total coliform samples; • Collection of chlorine residuals throughout system; • Isolation of storage tanks, sections of distribution system, wells, etc. • Due Diligence • Standard of performance that needs to be met; • “Have we done everything that would reasonably be expected to be done?” • Liability issues

36. Other NMED Security Outreach Activities • NMED/DWB efforts to obtain funding for an emergency water sampling fund to be used in potential water contamination incidents; • Possibility of increasing the Water Conservation Fund to include emergency sampling. • NMED/DWB will seek funding to purchase at least 2 sets of “Expanded Rapid Field Screening Test Kits”. Presently, existing technology is not what we need, but within a year or 2, it may be. • 2-3 different kits will test for all chemical and biological WMD, nerve gas, bio toxins and other contaminants that might be used in a terrorist attack. • NMED would hopefully be able to get the needed kits anywhere in New Mexico within 4 hours. • This will allow complete screening of potentially contaminated water. • These results will not be definitive, but they should indicate what if anything should be sampled for at a standard laboratory. • Based on the results, a limited number of samples should then be needed to be submitted to a standard laboratory at a much reduced cost.

37. Other NMED Security Outreach Activities (Cont’d) • NMED/DWB wants to create an emergency e-mail communication capability with all community water systems in NM. If no e-mail address available, then phone or pager number. • EPA’s new guidance “Drinking Water Security for Small Systems Serving 3,300 or Fewer Persons”. The DWB wants to begin an outreach program to begin getting smaller CWSs familiar with security and emergency response issues. NMED encourages these systems to create a vulnerability assessment and an emergency response plan (ERP) and upgrade security at their facilities. • Get the new ERP out to all community water systems

38. NMED Security Contacts • DWB Security Personnel • Co-ordinator – Darren Padilla, Santa Fe DWB office, 476-8631, darren.padilla@state.nm.us • District Security Personnel • District I Albuquerque – Jerry Lewis, 222-9534, jerome.lewis@state.nm.us • District II Santa Fe – Janice Dye, Raton Field Office, 445-3621, jan.dye@state.nm.us • District III Las Cruces – Ernest Valenzuela, 524-6300, ernest.valenzuela@state.nm.us • District IV Clovis – John Pijawka, Ruidoso Field Office, 258-3272, john.pijawka@state.nm.us

39. Reference Materials • EPA’s Security Website: www.epa.gov/safewater/security • This website is excellent and contains all of EPA’s security guidances and publications. • The following documents can be ordered free by calling the Safe drinking Water Hotline at (800) 426-4791. • EPA’s “Response Protocol Toolbox (RPTB): Planning for and Responding to Contamination Threats to Drinking Water Systems” • Module 2 “Contamination Threat Management Guide”, document # EPA-817-D-03-002 • Module 3 “Site Characterization and Sampling Guide”, document # EPA-817-D-03-003 • Drinking Water Security for Small Systems Serving 3,300 Persons or Fewer”, document #EPA-817-R-05-001

40. Reference Materials (Cont’d) • EPA’s “Response Protocol Toolbox” can be printed from EPA’s website: http://www.epa.gov/safewater/security • Click on: “Emergency / Incident Planning • Click on “EPA’s Response Protocol Toolbox • “Drinking Water Security for Small Systems Serving 3,300 Persons or Fewer” can be printed from EPA’s website: http://www.epa.gov/safewater/security • Under “Water Security Resources”, click on “Publications”. • Click on “Guidance”. • Scroll down to “Drinking Water Security for Small Systems Serving 3,300 or Fewer Persons”.