Rehearsing an Emergency Plan - des.state.nh.us

Rehearsing an Emergency Plan

at a small community water system

New Hampshire Administrative Rule 360.14 requires all community public water systems to
have a formal emergency plan (plan). Creating an effective plan is a several step process.
Maintaining an effective plan is a continuous process of which annual updates and plan
rehearsals are integral parts. This document is intended to describe a generalized process of
rehearsing an emergency plan at a small community water system. It is based on a fictional
water system, Nice Mobile Home Park, and it refers to information found in the sample
vulnerability assessment (assessment) and sample plan, also based on the fictional Nice MHP,
that are available from the DES.

Emergency Plan rehearsals (i.e. practice) are not required under 360.14. However, because
rehearsals are valuable as an evaluation tool for your plan, DES recommends that a small water
system rehearse its plan every two years.

Choose a Scenario to Rehearse

When a system compiles an assessment, it first identifies potential causes of emergencies.
Then it develops emergency scenarios and estimates impacts for each potential cause it
identifies. Nice MHP listed a major highway extending across its wellhead protection area as its
most dire potential cause of an emergency. The emergency scenario and estimated impact
from this cause, taken from their assessment, is inserted below:

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.

Nice MHP chose this emergency scenario to rehearse because of its most dire status, the
potentially serious estimated impact, and because they believed that this emergency would test
all aspects of its plan. They also realized that in real life this emergency would require a rapid
response from both itself and outside response agencies. It makes sense for systems to
consider factors such as those listed below when choosing an emergency scenario to rehearse:

1. How dire and what are the consequences? Choosing an emergency scenario that would
have dire consequences for your system, like that in the above example, makes sense
when deciding which scenario to practice. You want to be sure that your plan will work
as intended for an emergency that could have serious consequences for your system
(such as long-term or permanent loss of a source) were it to occur.

Rehearsing an Emergency Plan Small System – Page 2

2. How likely is the emergency to occur? The reasoning here is similar to that in #1. You
want to be certain that your plan will work as intended for an emergency that is likely to
occur. For example, Nice MHP experienced 2 major ice storm emergencies in 20 years,
so it is reasonable to assume that they will experience another. Consequently, ice
storms would be another sensible emergency scenario for them to rehearse. If an
emergency scenario is both dire to the system and likely to occur, then that scenario
should definitely be rehearsed.

3. Speed of response? All emergencies necessitate a response, but some response
actions must be faster than others. A drought can cause an emergency, but the
response does not have to be immediate because the impact of a drought occurs well
after its start, giving a system time to consider and act. Conversely, Nice MHP’s most
dire emergency scenario, the vehicle accident on the highway, would require an
immediate response time. It makes sense to both the system and outside responders,
such as the Fire Department, to rehearse an emergency scenario requiring a fast
response time because you want to be certain that your plan will achieve the fast
response actions needed for that particular scenario.

4. How extensive would notification be? Nice MHP established 5 separate notification
groups when they developed their plan: system users, unique system user,
service/repair contractors, local/state agencies, and abutting public water system. Not
all emergencies will require them to notify all 5 groups. For example, Nice MHP listed
distribution line breaks from freezing as an emergency scenario. If that were to occur,
they would have to notify some service/repair contractors, their impacted system users
(Nice is a 2-loop system, so not all of their users) and the unique user if impacted, but
they would not need to notify local/state agencies or the abutting system. Nice MHP
listed sabotage from a disgruntled employee as an emergency scenario. If pollutants
were introduced into their sources, they would have to notify all 5 groups. When
choosing an emergency scenario to rehearse, this factor is not as critical as the previous
three, but still should be considered.

Rehearsal Setup

Ideally, plan rehearsals should be unannounced. In the example of Nice MHP, the President of
the Homeowners Association, who has overall responsibility for managing an emergency at the
system, would probably choose the scenario and the time. The scenario would then be acted
out in real time without prior notice. Nice MHP listed 5 people on the chain-of-command in their
plan. Everyone on the chain-of-command must be involved in the plan rehearsal.

Practicing a plan in real time is essential if a plan is to be evaluated properly. For example,
according to their plan Nice MHP will use a telephone/email tree as their notification process.
To practice their plan in real time, they must actually use their tree to make sure it works – not
just “say” they are using it. In other words they must actually make the calls and send the
emails. It is only by really doing it that they will know how long it takes them to complete
notification or find out about any snags in their process.

The size of a water system is a factor when considering rehearsal setup. For small systems,
plan rehearsals primarily involve their process of notification. Small systems should know how
long it takes them to notify all necessary parties about a boil order or to implement water

Rehearsing an Emergency Plan Small System – Page 3

conservation measures, for example. The largest systems in New Hampshire will also need to
rehearse notification, but may also need to rehearse other concerns such as deployment of
hazardous waste containment actions or media communication, which may not be pertinent to
small systems. Also, usually the number of people on the chain-of-command is directly related
to the size of the system. Nice MHP listed 5 people. A very small system may only list 2 people
while a large system would likely list more than 5 people. As a rule-of-thumb, the more people
on the chain-of-command the more complex the rehearsal will be.

Plan Evaluation

The final aspect of a plan rehearsal is the evaluation of results. In the case of Nice MHP, the 5
people involved with the rehearsal should discuss its results and all observed problems should
be addressed. Any adjustments they make should be reflected in the next annual update of
their plan. Nice MHP’s notification tree is based on the Association Vice President notifying 12
initial households (out of 95 served by the system), who in turn each notify a pre-set list of other
households until all households on the system have been notified. An example of a problem
they might encounter is that one of the initial 12 households did not complete their notification
list for 5 hours, much longer than anticipated and they did not report this to the Association Vice
President, who is responsible for implementing system user notification. After evaluating their
rehearsal, they decide to make 2 changes: (1) to clarify to the initial 12 households that they
should report back any notification delays beyond 3 hours; and, (2) to improve the training of the
initial 12 households.

Additional Emergency Planning Self-Help Documents

DES has other documents to help small systems with emergency planning related issues, as
listed below.

1. Emergency Plan Guide for Community Systems.
2. Sample Emergency Plan and Instructions.
3. Sample Vulnerability Assessment and Instructions for small community water systems.
4. Tips For Water System Security.

Any Questions?

Johnna McKenna
Department of Environmental Services
Box 95
Concord, New Hampshire 03302-0095
603-271-7017 or [email protected]