Emergency Response Plan for Wastewater Systems in First Nations Communities

What is a Sewage Spill?

A sewage spill means the release or discharge of raw sewage or improperly treated sewage effluent into the environment in an amount that can cause pollution. It is usually associated with an out-of-the-ordinary event and not part of the day-to-day operations of a wastewater collection or treatment operation.

Action — Not Reaction

When a wastewater emergency situation does occur, you should immediately start taking the necessary actions to resolve it, not stand around wondering what you should do first or next. In order to be prepared, you have to be familiar with your community wastewater systems and be able to foresee various types of potential problems and causes that could lead to spills. Then you should identify solutions to each of those problems that could prevent or minimize the spills. Conditions that require public notification, requests for assistance and other possible concerns should all be identified in advance. The act of preparing a response to a potential wastewater emergency may actually help you prevent one from happening. By identifying and implementing mitigation measures you may be able to prevent or minimize the effects of an emergency. Mitigation measures should be part of your ERP and are discussed in more detail in Section 3.

The next sections of this Guide provide several examples of situations requiring an emergency response as well as recommendations for appropriate actions to be taken under such circumstances. The list is by no means exhaustive and you may be able to identify some other types of situations. This document should be used as a guideline for outlining your own community-specific ERP.

List of Contacts

At a minimum, your ERP should include a list of contact people and phone numbers for trouble shooting, servicing and assistance. This includes operators, repair people, government agencies, media representatives and community members. You should complete an ERP Contact List as shown in Appendix A of this Guide and post it on the wall of your office.

Your ERP should be organized into several logical sections so that information is easy to find. The following are some key elements that should be included in your ERP.

Introduction

The introduction of your ERP should explain its purpose, goals, and overall organization, and should describe the roles and responsibilities of community members involved, including the drinking water system operator(s). Stating a mission and goals for emergency response is an important first step because it helps focus on the important aspects of the plan. The mission statement should reflect the duty to provide proper wastewater treatment and disposal and to protect public health, the environment, infrastructure and property. The goals for your ERP should include:

• Assess the type and severity of the emergency
• Notify key contacts and authorities
• Take appropriate and timely emergency response actions
• Take action to minimize system damage
• Return the system to normal operation

Defining clear roles and responsibilities for system operators and other personnel during an emergency speeds up response time and helps eliminate confusion. System personnel needs to know who to report the emergency to, who is responsible for overall management of the emergency, who has decision-making authority and what their own responsibilities are. Large systems may have a variety of persons involved on-site, whereas small systems may only have one person, usually the wastewater system operator.

System Information

• Describe the sewage collection, treatment and disposal system as well as built-in redundancy features of the system.
• Describe equipment standard operating procedures.
• Describe procedures for connecting to portable pumps, switching to alternate power supplies and/or maintaining generators, including schematics of electrical systems in lift stations and wastewater treatment plants. They should be located beside the equipment they refer to.
• Storage location of tools and maintenance equipment.
• Storage location of your O&M Manual.
• Provide a map of your community that shows the location of the items such as the ones below to help in the fastest possible response:
  • wastewater collection sewers;
  • critical control points (e.g., lift stations, shut-off valves, manholes, cleanouts, overflow storage or bypassing facilities);
  • access routes, roads or trails to these critical control points;
  • wastewater treatment plant;
  • effluent disposal systems (i.e., ground disposal fields, outfalls, etc);
  • all built-in redundancy features of the facility;
  • high volume sewage discharge businesses if any;
  • drinking water distribution lines;
  • drinking water sources (wells, surface water intakes) and pump houses; and
  • other high-risk downstream receptors such as residents, schools, hospitals, daycare centers, long term care facilities, wells in unconfined aquifer or influenced by surface water, shellfish beds, recreational beaches and fish-bearing waters.

Mitigation Measures

System components identified in the previous section can become less susceptible to encounter problematic situations, which in turn may cause harm, if proper mitigation measures are in place. Mitigation measures refer to actions taken to eliminate or reduce the harmful effects of wastewater systems emergencies. By making a thorough evaluation of all the potential "trouble spots" or vulnerable points in your own system, you may identify steps you can take now that will prevent an emergency from happening later. The following items provide a guide to mitigation measures. Describe in your ERP all features that apply to your wastewater utility.

Mitigation of wastewater collection system failures consists of:

• cleaning sewer lines on a regular basis to remove grease, grit, and other debris that may lead to sewer backups;
• ensuring that groundwater and storm-water runoff infiltration and inflow are minimized ─ rain water entering the sewer pipe causes overflows;
• inspecting and maintaining manholes, sewer intakes and sewer lines for structural integrity;
• regular valve-testing—check locations of valve boxes to ensure that they have not been paved over;
• installing backup lift station at critical system control point, or installing a portable generator to provide protection against spills;
• providing storage to contain flow during a limited power outage; and
• educating system users about behaviors that can cause sanitary sewer blockage/overflows ─typical solids that buildup in the pipe and cause backups are grease, dirt, bones, tampons, paper towels, diapers, broken dishware, and garbage.

Mitigation of wastewater treatment process failures consists of:

• having power back-up sources and ensuring availability of fuel;
• getting trained on how to run utility systems manually when automated systems fail;
• having repair kits, spare parts, portable pump, etc.

Mitigation of impacts from spills consists of:

• determining the best methodology and location to bypass overflows due to equipment malfunction and/or power outages;
• arranging for alternate/emergency outfall; and
• having spill cleanup materials readily available and in a known location.

Potential Emergency Situations

When preparing your ERP, you should try to identify all situations which could have a negative impact on human health/safety or the environment. Some of the causes of spills and other malfunctions that you should identify include:

• Wastewater spill / broken sewer main
• Blocked sewer main
• Malfunctioning of wastewater treatment plant
• Pump/siphon failure
• Electrical control malfunctioning
• Power failure
• Malfunctioning of wastewater disposal facilities (i.e. ground disposal fields, outfalls)
• Flooding of wastewater treatment or disposal facilities
• Earthquakes damaging the system
• Snow/wind storm
• Fire
• Act of vandalism, terrorism or sabotage causing system disruption

The O&M Manual and standard operating procedures for your system may list typical system malfunctions and related emergency situations, methods to prevent them, and actions required when they occur. This information comes in handy when developing an ERP.

The potential impact caused by the above emergency situations can be ranked into three levels: minor, significant and major emergencies.

Section 4 provides some examples of potential emergency situations and possible responses, based on either causes or impact levels. Once you have identified all possible emergency situations and response actions for your system, you should record this information in ERP Action Lists as shown in Appendix B of this Guide.

Communication Plan

Communication plays a key role in how well you are able to respond during an emergency. You must be able to alert all the receptors of the spill from your system as soon as possible, especially if there is a possible risk to their health from contact with sewage. Section 5 provides more guidance on developing a simple and efficient emergency response communication plan.

Equipment Operation

Standard operating procedures for switching to alternate power supplies and/or maintaining generators, including schematics of electrical systems in pump houses, may also form part of your ERP, and should be located beside the equipment they refer to.

ERP Update and Training

Describe the ERP review and update process, evaluate the effectiveness of the ERP and provide information on the wastewater system's ERP training program. You need to update relevant components of the ERP when new wastewater facilities are added or the existing system is altered. You must update your emergency contact list once per year or whenever your contact information changes, whichever comes first. As an operator, you need to make yourself familiar with the emergency response plan when starting the job and when the ERP is updated. It is also important to practise your ERP. A wastewater emergency response drill (or mock emergency) is recommended once per year.

4.1 Responses based on causes

4.2 Responses based on impact levels of emergency

Public notices

A simple flyer/note to the affected people is an effective way to ensure that they are aware of the current situation regarding the sewage spill. The key is to make sure that everyone gets the message that an emergency has occurred and that the area is no longer safe for normal use. Some possible suggestions for the flyer/note include:

• Use bright paper to ensure that it is visible, especially for older community members (and always use the same color paper for a wastewater issue).
• Use readable, larger fonts so that the message can be read by everybody.
• Post or tape the flyer to each house; don't simply place it in a mailbox or through the mail slot, where it has the chance to be missed.
• Use the radio/telecommunications system if one is available in the community.

Phone trees/e-mail lists and web-based social networks

In the case of small or medium-sized communities, your communications plan may include organizing a "phone tree." This is a pre-arranged plan which allows every household in the community to be contacted by telephone with an important message from their neighbours. People who have been phoned have their own list of other people to phone, who in turn have the names of others to phone, and so on down the line until everyone on the system has been alerted.

Many small communities already have some kind of "phone tree" or e-mail list, etc., system in place so they can respond quickly to other emergencies, such as alerting local volunteer fire fighters. Talk to your local fire chief; you may be able to use the same system for an emergency involving your wastewater system. If your community has developed a broader EMP, use the pre-defined lines of communication. If you use a phone tree, it is very important to keep it up to date. Use and make the most of existing communication channels as much as possible, including chat rooms, Facebook, Twitter, etc. When using e-mail or other written communication, have a distribution list prepared in advance and have pre-written notification messages.

A "phone tree" probably isn't necessary for very small wastewater systems with only one/two or a dozen connections all located near each other. In these cases, assuming that you as the wastewater operator are already at the scene, you can pass the word around just by knocking on a few doors and getting others to pass the word around as well so that all the users are made aware of the problem right away. If you are using a "phone tree" to send out a message to your community members telling them not to use the sewer system (e.g., flushing toilets, doing laundry) during the spill, make sure that people who either don't have phone lines or e-mail, or who aren't in when the call is made also get the message.

Media

Local media such as radio, television and newspapers can also carry warnings to the community members if the situation is serious enough. Make sure you contact local media as part of your emergency planning to establish your credibility with them and to ensure that if you ever do have to call they will know who you are and how important it is to cooperate with you in alerting their readers or listeners.

Your emergency response communications plan should contain pre-written press releases in an appendix, to streamline your interactions with the media, and to make sure you don't miss any important or relevant information.

Appendix A. Emergency Response Plan | Contacts List Template

Appendix B. Emergency Response Plan | Actions Lists Template

TYPE OF EMERGENCY:

ACTIONS

CONTACTS

TYPE OF EMERGENCY:

ACTIONS

CONTACTS

TYPE OF EMERGENCY:

ACTIONS

CONTACTS

TYPE OF EMERGENCY:

ACTIONS

CONTACTS

Appendix C. Emergency Response Activity Record and Reporting Template

Appendix D. Notification of Release or Environmental Emergency

The Release and Environmental Emergency Notification Regulations designate (under CEPA 1999) and prescribe (under the Fisheries Act) the persons providing 24-hour emergency telephone service for the organizations operating for the provincial and territorial governments, enabling them to receive notifications that, otherwise, have to be made directly to Environment Canada. The list of designated provincial contacts is provided in the table below.

Appendix E. Material for Informing System Users/Community Members

Attach here your means of communication with system users/community members:

1. Phone tree
2. E-mail addresses list (save this list as a group in your e-mail software on your computer)
3. List of web-based social networks (save these links as "favorites" in your web-browser on your computer)

Attach here pre-prepared messages for distribution to system users/community members:

4. Flyers for door-to-door distribution (have a stack of these ready)
5. Pre-written e-mail messages (save these on your computer at an easy to find location)
6. Pre-written messages for posting on web-based social media
7. Pre-written press releases