Sample Vulnerability Assessment and Instructions for Small Community Water

Sample Vulnerability Assessment and Instructions for Small Community Water Systems (This document does not meet EPA Vulnerability Assessment Requirements for Systems serving 3,300 people or more) The purpose of a vulnerability assessment (i.e. contingency plan) is to identify potential causes of emergencies. Both unpreventable and preventable causes are identified. Once potential causes are identified, a system can take preventative actions to reduce their susceptibility to an emergency. As such, a vulnerability assessment (assessment) is a valuable management tool for all water systems. An assessment is not required under New Hampshire’s Emergency Plan Rule Env-Ws 360.14. An assessment is the preventative or long-term aspect of emergency planning, while the information required in 360.14 is the response, or short-term aspect. A system will greatly improve the effectiveness of its emergency planning by first doing an assessment, and then incorporating its findings into their formal emergency plan. This is why DES recommends that every system voluntarily decide to do an assessment. This sample assessment refers to a fictional water system called Nice Mobile Home Park. Instructions are in regular font and sample assessment sections are in italics. Unpreventable Emergencies Some emergencies are caused by reasons beyond the control of the water system. Floods, droughts, ice storms, earthquakes, power outages, vehicle accidents, and sabotage are examples. Step one of your assessment is to think about unpreventable emergencies that could impact your system. Has your system been impacted in the past by droughts, floods, ice storms, earthquakes, or any other natural cause that disrupts your flow of water? Have you been impacted by significant power outages in the past? High-risk land usage in the vicinity of your sources of water may also represent potential causes of unpreventable emergencies. The presence of highways, local roads, active railroad tracks, airports, landfills, industrial sites, underground or aboveground storage tanks, potential or known contamination sources, and animal herds in your wellhead protection area are examples of unpreventable land usage considerations. Definitions Wellhead Protection Area – the land area from which groundwater is likely to flow to a well. For bedrock wells, a circle around a well with a radius ranging from 1,300 to 3,600 feet dependent upon daily volume. For non-bedrock wells, an irregular shape based on existing hydrogeologic data. Sanitary Radius – a circle around a well with a radius of 150, 175, or 200 feet dependent upon daily volume. Potential Contamination Source – a facility that uses, stores, or handles hazardous substances in greater than household quantities. Sample Vulnerability Assessment – Page 2 Some high-risk land usage is preventable through source protection measures. However, as a rule of thumb, significant land usage concerns off your own property fall into the unpreventable category, particularly for a small system. Some land usage concerns on property that you do own may also be unpreventable (or nearly unpreventable), such as a major highway in your sanitary radius. Write down your unpreventable causes of emergencies. A lot of detail is not necessary – a simple list will do. It is more important to prioritize them from most to least dire. Another way to prioritize them is from most likely to occur to least likely. Below is a sample list for Nice MHP, listed from most to least dire. Nice MHP’s List of Unpreventable Causes of Emergencies 1. An interstate highway extends across our wellhead protection area, approximately 600 feet from our wells at its closest point. 2. Power Outage: Ice storms. 3. Disgruntled employees: Vandalism. 4. A large factory is situated in our wellhead protection area, approximately 1600 feet from our wells. 5. Two small-business potential contamination sources (a body shop and gas station) are situated in our wellhead protection area, approximately 700 feet and 1000 feet from our wells. Preventable Emergencies Other emergencies may be preventable. Step 2 of your assessment is to think about preventable emergencies that could impact your system. Age or obsolescence of equipment, poor system maintenance, poor system design, lack of spare parts, high risk land usage in the sanitary radius, and lack of source protection efforts are all preventable factors that can cause water system emergencies. Examples of ill-advised land usage in the sanitary radius include septic system leachfields, parking lots, parking of motorized vehicles and equipment, storage tanks, sheds, garages, dumpsters, and debris. Keep in mind that land usage on property that you own or control has a high degree of preventability. Proximity is important when considering impact to a well – in general, the closer a high-risk land usage is to a well, the greater the threat to the well. Consequently, you should pay particular attention to the land usage in your sanitary radius. As you did for unpreventable emergencies, prioritize your preventable causes from most to least dire or most to least likely to occur. Below is a sample list for Nice MHP, prioritized from most to least dire. Nice MHP’s List of Preventable Causes of Emergencies 1. Two septic system leachfields are situated in our sanitary radius. 2. A storage shed for park maintenance equipment is situated in our sanitary radius. 3. We do not have fences around our wells or storage tanks. 4. We do not have a formal water system equipment maintenance schedule. 5. A portion of one of our main distribution lines is not deep enough below grade to prevent freezing in severe winter conditions. Sample Vulnerability Assessment – Page 3 Assessment Tools Tools are available to all systems to help them compile their lists of potential causes of emergencies. DES is nearing completion of a project to assess the vulnerability to contamination of all public water sources in New Hampshire. DES sends an assessment report to each system owner after the report is completed. The reports contain information about land usage in the wellhead protection area and in the sanitary radius and they rate the various usages as high, medium, or low risk to your source(s). Check to see if you have received your source assessment report, and if so, you should refer to it for your assessment. Contact the DES at 271-7017 or jmckenna@des.state.nh.us with questions about your source assessment report. Another good source of information about land usage in your wellhead protection area and sanitary radius is copies of sampling waiver applications. The waiver applications contain specific information about potential contamination sources in your wellhead protection area and about land usage in your sanitary radius. Systems that already participate in the waiver program should have copies of applications in their files, or may be able to obtain copies from their certified operator. Contact the DES at 271-7017 or jmckenna@des.state.nh.us with questions about waiver applications. Both the assessment reports and sampling waiver applications include maps of your wellhead protection area. Another place to check for information is copies of sanitary survey letters. These letters may contain information about the condition of your system’s components. System Input As stated earlier, an assessment is a valuable management tool for all water systems. However, an assessment is only as good as the input that goes into it. The tools described above will help a system compile its assessment. However, the best source of information is the system, itself. You know your system’s history and it’s vulnerable areas better than anyone else. Do you have system components that are unreliable, aging, or lacking altogether? Does your system have design flaws that could cause an emergency? Is your pumphouse subject to vandalism that could result in an emergency? What is the condition of your system’s physical security – are your wells and storage tanks fenced in, or all your entry gates and doors locked? A thoughtful, objective, and careful appraisal of land usage around your sources and the condition and characteristics of your system is required to do a good assessment. That is why, as with your formal emergency plan, we recommend that the person(s) most knowledgeable about your system’s environment, equipment, infrastructure, and resources be at the forefront of authoring your assessment. Estimated Impacts Step 3 of compiling your assessment is to write out estimated impacts of your potential causes of emergency. You should consider potential impacts to the supply, storage and distribution components of your system. The best way to do this is to write out emergency scenarios that could develop if an emergency were to occur. Do this for each of your unpreventable and preventable potential causes, following the order that you listed them. Try to be brief and tothe-point. Below is a list of the estimated impacts for Nice MHP. Sample Vulnerability Assessment – Page 4 Unpreventable Emergency Scenarios at Nice MHP 1. Vehicle accident on the highway. Two streams extend underneath the highway and flow downstream toward our two bedrock wells, passing within 200 feet of our wells. The concern is the potential for a vehicle accident and a resultant release of gasoline or other engine fluids into the streams, which could carry the pollutants toward our wells situated only 600 feet from the highway. Although this has never happened, we consider this to be our most dire emergency scenario because it could result in long-term or permanent loss of one or both of our sources. This emergency scenario would impact the supply portion of our system. 2. Ice storms. Twice in the 20 years of Nice MHP’s existence, ice storms have caused power outages lasting 3 days. Both times the electric service line for our pumphouse extending along the pumphouse access road was downed, causing our water system to be out of power longer than the surrounding area. Lack of power impacts all of our system. 3. Disgruntled Employee. At this time, Nice MHP does not have a situation involving a disgruntled employee. However, about 5 years ago, a fired employee made verbal threats to the General Manager and Homeowners Association President. Because of our past experience we are including this as a potential emergency scenario. Sabotage could impact any component of our system, but would be most dire as a supply issue if pollutants were placed into our wells. 4. Factory in the wellhead protection area. According to the DES, the factory in our wellhead protection area has unlined wastewater lagoons and is a registered user of hazardous materials. We are concerned about contamination from these lagoons or from improper storage or disposal of their hazardous substances. This would impact us as a supply problem. 5. Two small-business potential contamination sources. Both the body shop and the gas station are situated at lower elevations than our wells, so we consider this our least dire unpreventable emergency scenario. However, we are listing this as an emergency scenario because of potential pollution risk from the gasoline at both facilities. This would impact us as a supply problem. Preventable Emergency Scenarios at Nice MHP 1. Two septic system leachfields in our sanitary radius. At their closest points, one septic system is situated approximately 180 feet from source 002 and the other is approximately 110 feet from source 001. We are concerned about nitrate and microbiologic contamination from these leachfields, as well as contamination from improper disposal of household hazardous wastes. Adding to our concern is that one of the leachfields has a history of not being in good working order. We consider this to be our most dire preventable emergency scenario and one that would impact us as a supply problem. 2. Maintenance storage shed in our sanitary radius. The shed is approximately 140 feet from source 001 and 180 feet from source 002. Materials stored inside the shed include 5-gallon containers of gasoline, paint, cleaners, oils, and lawn care products. Sample Vulnerability Assessment – Page 5 Maintenance staff performs basic small engine service and fueling inside and next to the shed. We are concerned about contamination from inadvertent or accidental release of pollutants in the shed, particularly the gasoline. We consider this to be our second most dire preventable emergency scenario. This would impact us as a supply problem. 3. No fencing around our wells and storage tanks. We are concerned that our lack of security makes us vulnerable to vandalism or sabotage. This could impact us as a supply or storage problem. 4. No formal system equipment maintenance schedule. The water system at Nice MHP is over 20 years old. Nearly all of the original system components are still being used including pumps, treatment system, pumphouse controls, storage tanks, distribution lines and shutoff valves. We are concerned that the potential for breakdowns of our major components is increasing as time goes by. This could impact any of the supply, storage and distribution components of our system. 5. Pipe breaks due to freezing. Eight years ago we had a distribution line break caused by freezing in the pipe. Water service in that loop was disrupted for nearly two days. Twelve years ago we re-graded and repaired a 250-foot section of our main park road. An inadvertent result of this work is that the distribution line underlying this section of road is now not deep enough to be below frost line in severe winter conditions. Line breaks impact our distribution system. Tie-in to Emergency Plan Once you complete the above steps your assessment is complete. Should an emergency occur at your system, response actions are established in your emergency plan. As stated at the beginning of this document, a system will improve the effectiveness of its emergency planning by first doing an assessment. In light of that, it should be useful to illustrate three examples of how Nice MHP might incorporate the findings of this assessment into its emergency plan. See below. 1. Nice MHP listed the potential of vehicle accidents on the highway as its most dire unpreventable emergency scenario. They should be certain to list appropriate fire and police response numbers in their emergency plan. More importantly, they should meet with local fire and police officials to express their concerns about what could happen to their wells should this scenario occur, and they should invite them to observe the setting of the wells, streams, and highway. Local emergency response agencies will be better prepared to protect the wells at Nice MHP if they know about their vulnerable setting. Additionally, this would be a good emergency scenario for Nice MHP to choose for their plan rehearsals. 2. Nice MHP listed the septic systems in the sanitary radius as a dire emergency scenario. They should be certain that their emergency plan includes a septic tank pump firm on their service/repair notification list and take the further step of meeting with the septic pump firm to discuss priority emergency service if necessary. 3. Nice listed lack of a formal equipment maintenance plan and the increasing obsolescence of their system as a preventable emergency scenario. They should be Sample Vulnerability Assessment – Page 6 certain that their emergency plan service/repair notification list includes specialists for all major system component repair, including pumps and controls, treatment system, storage tanks, distribution lines and shutoff valves. Planning Actions It was also stated at the beginning of this document that an assessment is a valuable management tool. Below is a list of planning steps Nice MHP could take based on the findings of their assessment. 1. Apply for DES financial assistance (grants or loans) to move the septic systems out of the sanitary radius and to re-set the too-shallow portion of the distribution line. 2. Send educational materials to the users of the septic systems in the sanitary radius giving them tips about how to safely store and dispose of household hazardous materials. They already do this if they participate in the sampling waiver program. 3. Send educational materials to the factory and two other potential contamination sources in the wellhead protection area. The materials will inform the facilities that they are in a sensitive groundwater area and ask them to be careful with hazardous substance disposal. They already do this if they participate in the sampling waiver program. 4. Move the storage shed out of the sanitary radius. Instruct all personnel who use the storage shed to follow DES Best Management Practices for the Protection of Groundwater at the storage shed. 5. Budget for burying or otherwise improving the electric line serving the pumphouse so it can better withstand ice storms. 6. Budget for fence installation and research other feasible water system security measures to take. 7. Institute a formal water system equipment maintenance and replacement schedule. Additional Emergency Planning Self-Help Documents DES has other documents to help small systems with emergency planning related issues, as listed below. 1. 2. 3. 4. Emergency Plan Guide for Community Systems. Sample Emergency Plan and Instructions. Rehearsing an Emergency Plan at a Small System. Tips For Water System Security. Any Questions? Johnna McKenna Department of Environmental Services Box 95, 6 Hazen Drive Concord, New Hampshire 03302-0095 603-271-7017 or jmckenna@des.state.nh.us