Transcript FERC Security Program for Hydropower Projects

Current US Security
Practice for Hydro Facilities
Outline of Presentation
- Responsibilities of FERC and Owners for security
of US hydro projects
- FERC's Security Program for Hydro Projects (copy
sent before – on FERC website – www.ferc.org)
- Owners Security Assessments and Actions
Required by FERC
- Charleston Workshop – March 2003
- Current status – FERC presentation at HV 2004
- Vulnerability Assessment Methodologies - RAM-D,
VA Analysis, DAMS-VR
- Review of Typical Cases
- Key Issues
6th October 2004
CESI Security Workshop, Milan
Robin Charlwood
Responsibilities for Security at
US Hydropower Projects
 Federal dams
– US Bureau of Reclamation (USBR), US Army Corps of
Engineers, etc.
 Non-federal dams for hydropower
– Federal Energy Regulatory Commission (FERC).
 Other dams
– Association of State Dam Safety Officials (ASDSO).
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FERC Security Program for
Hydropower Projects
 Program was distributed to licensees/exemptees in
June 2002.
 FERC received comments and recommendations
from licensees and other agencies.
 FERC Issued Revision in November 2002
 All Licensees responded to FERC by September
30, 2003
 Security measures have been implemented
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Owners Security Assessments
Actions Required by FERC
Licensees/exemptees will be responsible for:
• Security at their projects, vulnerability and risk assessments of their
projects (as appropriate), security upgrades, and communicating with
local law enforcement and nearby dam operators.
• Having a single designated contact to receive FERC security alerts.
• Having a designated contact to the FERC for other security related
communications.
• Ensuring that the corporate security officer be involved with all security
associated activities.
• Making sure that security measures do not conflict with License
requirements.
• Integrating the EAP, Security Plan, and Recovery Plan for their projects,
if that project has those documents.
• Communicating to the FERC Dam Safety staff and nearby dam operators
regarding security breaches or incidents, if not expressly restricted by
law enforcement agencies.
6th October 2004
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Requirements for FERC dams:
Requirement
Group 1
Group 2
Group 3
Security Assessment
Yes (1,4)
Yes (1,4)
No (2)
Vulnerability Assessment
Yes (1,5)
No (2,5)
No (5)
Security Plan
Yes (1)
Yes (1)
No (2)
Integration of Security concerns
and EAP procedures
Yes (3)
Yes (3)
No (2)
1 Completed by September 30, 2003.
2 Although not required, this item is strongly encouraged.
3 Integration should begin immediately, and be revised as conditions change and
documents are refined or developed.
4 A separate Security Assessment may not be required for a dam if a more detailed
Vulnerability Assessment is completed for that facility that addresses the need for security upgrades.
5 A Vulnerability Assessment must be completed prior to the FERC approval of requests
for permanent closures of recreational, or other project, facilities.
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Documents Required by FERC
Security Assessment - An evaluation of the current
state and appropriateness of the onsite security
system and what needs to be done at a project or
facility to address concerns regarding security,
such as installation of fences, gates, cameras,
increased guards, etc.
This assessment will identify if any security enhancements
are needed, and specifically what those enhancements
consist of. The recommendations made from the Security
Assessment will lead to improved security measures and
should be incorporated into the corporate Security Plan
(see definitions, below).
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Documents Required by FERC
Vulnerability Assessment (VA) - addresses the following:
1) it identifies the "weak points" or vulnerable project features;
2) it assesses the potential threat to a facility as based on organizations or
people who may wish to cause harm to the facility, a history of security
incidents, and information received from the FBI or other law
enforcement agencies specific to your area or facility;
3) it addresses the consequences of such an attack, and;
4) it addresses the effectiveness of the security system to counter such an
attack. These factors should be addressed with a fair degree of
confidence, with some supportive documentation to substantiate the
assumptions.
VAs must be completed for all Security Group 1 Dams, and for any dams
where there is a request to close usage (i.e., recreation or roads) of
project lands for security reasons.
A Security Assessment may be incorporated within a detailed VA.
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Documents Required by FERC
Security Plan - A document that characterizes the response to
security concerns at a project or facility.
The Security Plan may include specific features of the project
security program, such as fences, surveillance cameras, etc.
and company procedures to follow based upon changing
threat conditions or situations.
The Security Plan can be very simple or very complex based
upon the specifics of the site as well as the assessment of
the potential threat to the facility.
6th October 2004
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Documents Required by FERC
Recovery Plan - A document describing the actions an
organization will take to recover from a disaster. The
disaster can be natural or caused by criminal activity.
A Recovery Plan in this program generally refers to the
pre-planned actions allowing a utility to continue, or
quickly restore, generation of power, or otherwise function
in its intended purpose.
This document is also known as Utility Recovery Plans,
Continuity of Operation Plans, etc. This document can be
specific to a hydropower dam or reservoir, and/or part of
the entire utility company recovery plan.
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Documents Required by FERC
Emergency Action Plan (EAP) - A document describing the
actions a dam owner/operator takes if a problem exists at a
dam, whether due to natural causes or sabotage.
Actions include identifying and assessing the problem,
mitigating the problem if possible, and notifying the
emergency management system to protect human life and
property.
Inundation studies and notification call charts are included
in EAPs.
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Documents Required by FERC
Integration of plans - In this program, "integration" of plans is defined as
ensuring that there is continuity between the many company
documents that may exist, such as Security Plans and Emergency
Action Plans (EAPs). Emergency and response actions arising from
procedures contained in company documents should be internally
consistent, with few if any procedural conflicts. Authors and
administrators of documents within a company should ensure that
proper coordination has been achieved and, as an example, the security
personnel understand the procedures contained in the EAP and vice
versa.
"Integration" does not mean that security information should be
incorporated into an EAP, which would have a wider distribution than
a Security Plan.
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Current Status of FERC Program
Summary of Presentation by
FERC Physical Infrastructure Security Specialist
at
HydroVision 2004
Montreal, Quebec
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SABOTAGE OF DAMS
A historical perspective…
Mohne:
Breach: 253 x 72 feet
Discharge: 310,000 cfs
Wave: 33 feet high
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Eder:
Breach: 164 feet
Discharge: 300,000 cfs
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THE CURRENT (11/99) TSWG BLAST CARD
WHAT 1,010 POUNDS OF H.E. DETONATED
IN A SCHOOL BUS LOOKS LIKE
KHOBAR TOWERS – TANKER TRUCK
WITH 15,000 LBS. PLASTIC EXPLOSIVES:
LEFT A CRATER MORE THAN 15 FEET
DEEP
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RESULTS OF FERC LICENSEE
VULNERABILITY/SECURITY ASSESSMENTS
Licensees Completed Vulnerability/Security Assessments
on Sept 30, 2003
FERC received 273 Summary Reports for the
September 30, 2003 Deadline (many reports cover multiple dams).
• All Security Group 1 and Group 2 Dams (1,050) Completed Studies
• Used to Assess and Upgrade Security Where Necessary
• Used as Baseline for Future Needs
The following are cumulative results learned from the submittals:
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RESULTS OF LICENSEE VULNERABILITY/SECURITY ASSESSMENTS
Post 9/11 Interim Measures
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RESULTS OF LICENSEE VULNERABILITY/SECURITY ASSESSMENTS
What Were the Suggested Upgrades Identified by the Assessments?
Recommendations
80
70
60
50
40
30
20
10
0
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An Issue - Recreation at Hydropower Projects
What does this mean for
licensees and
recreational access at
FERC Hydropower
Projects?
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RECREATION REQUIREMENTS
In addition to approved recreation plansLicensees are required to provide free public access, to a
reasonable extent, to project waters and adjacent project
lands … for the purpose of full public utilization of such
lands and waters for navigation and for outdoor recreation
purposes… (L-forms)
Provided, that the licensee may reserve from public access
such portions of the project water, adjacent lands, and
project facilities as may be necessary for the protection of
life, health, and property.
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What Can A Dam Owner Do?
 Provide additional security measures
including personnel, lights, and cameras
 Work closely with local law enforcement
agencies to coordinate security
 Work with local recreation groups
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Options to Permanent Closure
Closures based on specific
threat
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Options
 Relocate a facility further from the dam or vulnerable
area in order to provide public access
Example- A licensee relocated its visitor center
further from the perceived vulnerable area in order to
continue to provide educational programs
 Opening access points during specific times such as
peak weekends, special events, and holidays.
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Points To Consider
 Stay alert and informed.
 Notify appropriate Regional office and the
Washington office of changes at your project.
 Review and revise, where appropriate, the signage at
the project to reflect any changes to the public access
at the projects.
 Attend local community meetings, meetings with
local recreation groups such as anglers or whitewater
rafting groups.
 Put notices in the local newspapers in order to inform
the public of changes.
6th October 2004
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Vulnerability Assessment
Methodologies
 RAM-D & RAM-W – by Sandia Labs
 VA Analysis – simplified method
proposed by FERC in April 2003
– available for use by Owners
 DAMS-VR – latest method proposed by
FERC for their monitoring of Licensees
Security Programs – available from
FERC on a controlled basis
6th October 2004
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RAM-D - Risk Assessment
Methodology for Dams
Developed for the:
Interagency Forum for Infrastructure Protection
(IFIP)
by:
Sandia National Laboratories
Albuquerque, NM
Proprietary Information – Available under License only
6th October 2004
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RAM-D - Risk Assessment
Methodology for Dams
 Risk Equation R = PA * C * (1 – PE)
PA = Likelihood of attack
C = Consequences of the loss from the attack
PE = System Security effectiveness
(1 – PE) = Likelihood that security system is not
effective against an attack
R = Risk associated with an adversary attack
Proprietary Information – Available under License only
6th October 2004
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RAM-D - Risk Assessment
Methodology for Dams
 RAM-D addresses these items by a very
systematic and fully documented process:
– Screening events, consequences
– Planning, develop fault-tree, threat estimates,
consequences, assign priorities
– Site survey, detection, delay, response
– Analysis of “Adversary Sequence Diagrams”, system
effectiveness, calculate risks
– Risk Reduction, “Design Basis Threat”
– Upgrade evaluation, cost, operation, schedule, public
opinion
– Final Report
Proprietary Information – Available under License only
6th October 2004
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VA Analysis (Simplified Ram-D)
I.
1.
2.
3.
Threat Analysis (T)
Determine the presence and motivation of a
Threat
Does the above group have personnel/resources
sufficient to carry out the failure consequences
(specific targets to be identified in Steps 4 and 5)?
Estimate number of attackers, equipment, tools,
vehicles, weapons, and tactics for each group
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VA Analysis (Simplified Ram-D)
II. Consequences (C)
4. Life Loss
4A. Dam Failure
4B*. Vulnerable Feature (i.e., Gate) Failure
5. Dam Mission (Power, Water Supply, Flood Control,
Navigation, Environmental)
6. For each group (from Step 2) record both Life Loss
Consequences:
7. For each group (from Step 2) record both Dam Mission
Consequences
8. Record the highest of above four Consequences for each
group identified from Step 2 (Low, Medium or High)
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VA Analysis (Simplified Ram-D)
III. Security System Effectiveness (S)
9. Estimate Detection/Assessment Ability (DA):
Low
Medium
High
10. Estimate Delay Time (time from first detection to
action causing failure) (DT = minutes)
11. Estimate Effective Response Time (time from
first detection to deployment of sufficient
response force) (RT = minutes)
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VA Analysis (Simplified Ram-D)
Security System Effectiveness (S) continued
12. Determine Security System Effectiveness (from
Steps 9, 10, and 11)
III.
DA=Low
DA =Medium
DA=High
DT < RT
Low (S)
Low (S)
Medium (S)
DT > RT
Low (S)
Medium (S)
High (S)
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VA Analysis (Simplified Ram-D)
III.
Security System Effectiveness (S) continued
13. Compare maximum Consequence (C) (Step 8) for each identified
group to the Security System Effectiveness (S) (Step 12) to
determine the Attack Potential (AP) for that group:
Low (S)
Medium (S)
High (S)
Low C
AP = 1
AP = 1
AP = 1
Medium C
AP = 2
AP = 1
AP = 1
High C
AP = 3
AP = 2
AP = 1
If the Attack Potential is “1” for all groups, then no further analysis is
necessary. If the Attack Potential is “2”, or “3” for any group, then
compare it to the Threat Analysis for that group.
6th October 2004
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VA Analysis (“Simplified Ram-D”)
III.
Security System Effectiveness (S) continued
14. Compare Attack Potential (AP) (Step 13) to Threat (T) (Step 2) for
each identified group:
Low Threat (T)
Medium Threat
(T)
High Threat (T)
AP = 1
No
No
No
AP = 2
No
No
Yes
AP = 3
No
Yes
Yes
If “Yes”, security enhancements are strongly suggested; continue with a
Security Assessment. If “No”, security enhancements may not be needed
unless the Threat Level increases for that group. Develop unified security
upgrades to address the identified weaknesses and vulnerabilities.
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DAMS-VR
 Available on request from FERC
Request from:
www.ferc.org/industries/hydropower/safety/security.asp
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DAMS-VR
Step
SUMMARY OF METHODOLOGY –
REFER TO COMPREHENSIVE MANUAL
FOR DETAILED INFORMATION
Description
Table
Remarks
1
Consequence Rating Range
1
Each agency defines the range of
consequence values. These values are
used to modify Table 1 to agency
needs.
2
Benefits of project or facility
-
Define all project benefits
3
Project and Asset Consequences (C)
1
Assign the project a C value. Develop
a list of assets. Assign individual assets
C values, using numeric values from 110. Determine which assets are critical.
4
Vulnerability (V) of individual dam
structures and asset
4
Define the vulnerability of each
identified dam structure and critical
asset, using numeric values from 1-10
5
Essential Elements of information (EEI)
and Prioritized Intelligence
Requirements (PIR)
-
Develop a list of questions for a Threat
Specialist to quantify the Threat in the
area. Define actions needed to
compromise assets.
6
Probability of Loss (L) of each asset
3
Determine the Probability of loss for
each critical asset, using numeric
values from 1-10.
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DAMS-VR
Step
Description
Table
7
Loss Factor Rating (LF)
8
Priority Rating of Critical Assets
9
-
Remarks
LF = (V x L) for each critical asset.
4&5
Determine asset Priority Rating: Highly
Probable, Probable, Moderately
Probable, Improbable, or Extremely
Improbable. Drop assets with ratings of
Improbable and Extremely Improbable.
Threat (T) rating for individual Critical
Asset
6
Determine a Threat value rating (1-10)
for each Critical Asset.
10
Security Effectiveness (S) of individual
Critical Assets
7
Determine a security value rating (110) for each Critical Asset.
11
Asset Security Risk (ASR) of
individual Critical Assets
-
ASR = C x (V + L + T + S)
12-14
Evaluate ASRs and other data
-
Evaluate data; make recommendations
to reduce risks; obtain preliminary cost
estimates; prepare final report.
6th October 2004
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Review of Typical Cases
 A large urban water supply and hydro utility
 A large remote hydro project and arch dam
 A small high hazard arch dam
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A Large US County Water Authority
• Wholesale Provider
• 90% Supply
• 2+ Member
Agencies
• 3 Million
Residents
• $100 Billion
Economy
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Existing Infrastructure
•
5 Pipelines (274 Miles)
•
1600 Structures
•
Dam & Reservoir
•
2 Hydro-generation Facilities
•
4 Pump Stations
•
260 Employees
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Major System Changes
•
•
1989 Capital Investment Plan Initiated ($1 B)
Pipelines, Pump-stations, Dam and Reservoir
Emergency Storage Project ($800 M) including
Watershed and Dam Operations (90,000 af additional
storage)
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Vulnerability Assessment
Vulnerability Assessment
•
In-house HA/VA Nov. 2001
•
VA’s (RAM-W & RAM-D) Completed 2002 / 2003
•
Cyber Security Evaluation Completed 2002
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Physical Security
Physical Security
•
Fencing (anti-vehicle)
K-rail/Jersey Barrier
Bollards
Clamshells
Landscape Removal
Proximity Cards
•
Increased Stand-off Distance
•
Close or Redirect Roads
•
•
•
•
•
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Lock Changes ($40 K)
Welding Hatches & Nuts
Double Screen Vents
Earth Berm & Rocks
Gates & Signs
CCTV
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Operational Security
Operational Security
•
Increased Patrols (log in required)
•
Emergency Water Allocation Plan
•
Increased Drills / EOC Activation
•
Purchased EOC Software (E-team)
•
Increased WQ Sampling
•
Security Workshops
•
Neighborhood Watch
•
ERP to ICP
•
Security Plan & Matrix
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Communication/Coordination
Communication/Coordination
•
•
•
•
•
•
Law enforcement Tours (Sheriff, Local PD, FBI)
Threat Briefings, Maps, Exercise, GPS Coordinates
Member of FBI InfraGard Program
Security – Operating Head (interagency meetings)
Communication – Need to Know
Tours – Appointment Only
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A Hydro Project Security Plan
Security Procedures: Threat levels may be set in accordance with local conditions at each generation site. Security procedures will be put in place
that are specific to each site. Procedures will be updated annually and maintained at each powerhouse and by the Generation Plant Operations
Director.
GREEN
BLUE
Normal plant access with passive security measures in place to keep general public from
non-restricted areas and to protect public from normal hazards and to prevent theft and
Low risk of
No specific threat to vandalism. Employees will carry current identification cards and residents will have
terrorist attack generation facility
current photo identification.
General terrorist
General risk of threats to national
terrorist attack infrastructure
Restricted public access. No general access to dams or powerhouses. Employees are
expected to be inquisitive about strangers and vehicles in unauthorized areas and to
report suspicous activities to proper authorities. Contractors must make prior
arrangements to be on site with site manager or powerhouse staff. All personnel and
contractors must have proper photo identification.
YELLOW
Terrorist threat to
Significant risk area predicted in
Response will be the same as for blue level advisory with addition of security staff on site
of terrorist
vicinity of generation should situation require higher level of security. Equipment and vehicles may be
attack
facility
inspected.
ORANGE
Tours suspended. Personnel and contractors must have proper photo identification if
requested by security personnel. Visitors will be allowed only for official business and
must have prior approval and proper identification. Gates may be closed with access by
employees only. Onsite security personnel may be assigned to guard entrance gates
and the dam access gates during business hours. Visitors' log will be used and nonemployees will be issued permits to be on site. Security staff may inspect equipment
and vehicles. Staff will review evacuation plans and staffing arrangements in the event that
threat is elevated to highest threat level (red).
RED
Credible report of
terrorist attack
High risk of
and/or attack is
terrorist attack imminent
Generation site is
Severe risk of
threatened or
terrorist attack
attacked
Plant is locked down and only authorized powerhouse crew personnel will be admitted
onto the project site. Security personnel will be on site. Powerhouse staff will verify all
entrance gates/doors are locked. Employees will carry proper photo identification at all
times.
Equipment will be secured for automatic operation. The site will be evacuated except for
the operating employees required to protect the public from facility failure downstream of
the site. Employees will carry proper photo identification at all times.
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A small high hazard arch dam
See separate VA Analysis results of:
1. Existing security
2. Upgraded Security
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Key Issues
As discussed at a US
Security and Emergency
Preparedness at Dams
Workshop
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Workshop – March 2003
Three detailed panel discussions covered:
• Planning and Managing Security
Concerns
• Preparing for an Emergency
• Responding to an Emergency
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Workshop – March 2003
Planning and Managing Security Concerns
1. Difficult to protect against a concerted attack (pre-warning only)
* What constitutes an appropriate response to larger threats?
2. Conflicting regulations from different agencies may create
conflicts
* Varied warnings from various agencies
3. Balancing the flow of information vs. protecting critical
information
4. Information sharing between dam owners
* Reporting incidents
* Coordinating with u/s and d/s owners
5. Sweeps of al-Qaeda intelligence: is there proof of dam targeting?
* Intelligence analysis: looking for patterns
6. Nation-wide security guidance (due diligence)
7. Consistency in addressing recreational concerns
8. R&D (waterborne routes, gate protection, emb. crest protection)
9. Identification checks at conferences and workshops
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Workshop – March 2003
Preparing for an Emergency
1. Real-time river forecasting needs coordination w/dam owners
2. Each state should pass regulations for information protection
3. How best to provide emergency information to the public
* Keeping parents away from children in schools
4. GIS compatibility with various agency mapping systems
5. Coordination of security with dam safety meetings/exercises
6. FERC guidance on “sanitizing” EAP content
7. Education that immediate response comes from local law enf.
* FBI needs to be contacted, but will come in later
8. National consistency in emergency nomenclature wording
9. Closely follow DHS development of national model for ICS
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Workshop – March 2003
Responding to an Emergency:
1. How are response costs paid for a dam failure?
2. Determining who needs to be evacuated versus who does
not
* Determining sheltering needs more accurately?
3. How best to involve amateur radio operators in a response
4. Electronic (GIS) versus paper inundation maps
5. Prioritization of restoring public services during recovery
6. Importance of flood depth data to responders
7. Communication systems reliability
* Cell saturation / land lines / radio
8. Dam owner representative inserted into Emergency Ops
Center
* Coordinating/controlling public information
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