NMED's Drinking Water Emergency Response Plan and other Security

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

NMED's Drinking
Water Emergency
Response Plan
and other Security
Issues
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Introduction
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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.
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Topics of Discussion
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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
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NMED/DWB’s Drinking Water
Emergency Communication Protocol
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Once the incident is confirmed, the system must fill out the
reporting form and make 3 phone calls:
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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.
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Emergency Communication Protocol (Cont’d)
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The NMEOC will immediately call the following agencies:
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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.
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Emergency Communication Protocol (Cont’d)
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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
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Emergency Communication Protocol (Cont’d)
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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.
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NMED/DWB’s Drinking Water
Emergency Response Plan
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Designed to help the water system and DWB security
personnel/oversight staff work together efficiently to respond
appropriately.
It consists of:
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A cover page and Introduction
A Table of Contents of the different types of emergencies
The 6 chapters
Appendices
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Emergency Communications Protocol
Site Characterization
ERP Resources and tools
Needed Sampling Equipment
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NMED/DWBs ERP (Cont’d)
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Chapters 1 – 4 are divided into 6 sections
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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
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NMED/DWB’s ERP (Cont’d)
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Chapters
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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);
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NMED/DWB’s ERP (Cont’d)
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Chapters Cont’d
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Chapter 4. Natural Disasters or Accidents;
Chapter 5. Acute Fecal Coliform Contamination
Chapter 6. Acute Nitrate Contamination
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NMED/DWBs ERP (Cont’d)
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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.
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NMED/DWBs ERP (Cont’d)
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Responsibilities of the DWB District Security Coordinator (potential
contamination) include:
 Takes the lead for NMED/DWB
 Establishes chain of communication with NMEOC
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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
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NMED/DWBs ERP (Cont’d)
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Responsibilities of the DWB Oversight Staff Person
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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.
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NMED/DWBs ERP (Cont’d)
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Responsibilities of the Water System (Potential
contamination)
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Water system evaluates the threat
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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.
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NMED/DWBs ERP (Cont’d)
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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.
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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.
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NMED/DWBs ERP (Cont’d)
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Public Notification (Potential Contamination Incident)
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When to issue public notification
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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.
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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.
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If there is no possibility of distribution system contamination,
public notification is not necessary.
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NMED/DWBs ERP (Cont’d)
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General types of public notification for potential
contamination
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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.
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Chapter 5. Acute E-Coli
Contamination
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4 ways an acute bacti violation occurs
Chronological listing of events, requirements, etc.
Appendix 5A
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Technical assistance checklist for finding the cause of an ecoli violation
Appendix 5B
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“Boil Advisory” supplemental information
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Chapter 5 (Cont’d)
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Four ways an acute bacti violation occurs:
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“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.
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Chapter 5 (Cont’d)
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Chronological listing of events (highlights only)
 Notification of system or NMED/DWB
 Alerting of NM Department of Health (NMDOH)
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System is sent (e-mail/fax) a blank “Boil Advisory” for their use.
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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 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
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Go over water system’s public notification requirements
If possible, determine cause of contamination (see Appendix 5A),
Discuss pertinent issues.
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Chronological Listing of Events (Cont’d)
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Public Water System Public Notice Requirements
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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:
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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
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Chronological listing of events (Cont’d)
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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.
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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
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Second press release rescinding the “Boil Advisory”
Water system is called to rescind public notification and “Boil
Advisory”.
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Chronological listing of events
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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.
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NMED should require this in certain situations
The proposed “Groundwater Rule” may require this.
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Chapter 6. Acute Nitrate
Contamination (highlights only)
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Quarterly nitrate sampling
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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.
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Chapter 6. (Cont’d)
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Chronological Listing of events
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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.
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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.
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Chronological listing of events (Cont’d)
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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).
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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
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in writing by NMED/DWB.
NMED/DWB with input from system will decide upon required public
notice delivery.
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Chronological listing of events (Cont’d)
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NMED/DWB sends an acute nitrate/nitrite or nitrite acute
violation letter to the water system.
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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.
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NMED DWB’s Emergency Test Kit Program
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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.
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Site Characterization
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Process to determine if hazardous material, WMD, etc. was
brought into the site and identify it if possible.
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Includes:
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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)
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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.
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Site Characterization (Cont’d)
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If someone has breached your security and entered a
facility:
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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.).
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Site Characterization (Cont’d)
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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).
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Site Characterization (Cont’d)
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Initial Site survey from outside the compound
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Complete while radiation screening is proceeding
Scan the area for evidence of what might have been brought
into the site
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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.
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Site Characterization (Cont’d)
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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;
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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.).
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Site Characterization (Site Inspection) Cont’d
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Identify additional/secondary damage/potential water
contamination sites within the water system.
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Additional activities associated with the site inspection
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If there is an additional intrusion/secondary damage site,
conduct “Site characterization” wherever necessary.
Collection of total coliform samples;
Collection of chlorine residuals throughout system;
Isolation of storage tanks, sections of distribution system, wells,
etc.
Due Diligence
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Standard of performance that needs to be met;
“Have we done everything that would reasonably be expected
to be done?”
Liability issues
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Other NMED Security Outreach Activities
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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.
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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.
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Other NMED Security Outreach Activities (Cont’d)
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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
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NMED Security Contacts
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DWB Security Personnel
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Co-ordinator – Darren Padilla, Santa Fe DWB office, 476-8631,
[email protected]
District Security Personnel
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District I Albuquerque – Jerry Lewis, 222-9534,
[email protected]
District II Santa Fe – Janice Dye, Raton Field Office, 445-3621,
[email protected]
District III Las Cruces – Ernest Valenzuela, 524-6300,
[email protected]
District IV Clovis – John Pijawka, Ruidoso Field Office, 258-3272,
[email protected]
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Reference Materials
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EPA’s Security Website: www.epa.gov/safewater/security
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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”
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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
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Reference Materials (Cont’d)
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EPA’s “Response Protocol Toolbox” can be printed from
EPA’s website: http://www.epa.gov/safewater/security
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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”.
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