Emergency Management Plan Revision of May 1, 2011



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FOLLOW-UP

Safety Manager shall conduct a Critique of all incidents classified as Level 2 or higher, and shall properly document and follow-up on all findings and resulting corrective actions and/or recommendations.




Telephone System Failure


      1. SITUATION

GSWSA relies on both its internal telephone network (Mitel), and the external telephone system (HTC) to conduct routine business on a daily basis.
A problem with either system could potentially render GSWSA’s telephones inoperative.


      1. THREAT or HAZARD INFORMATION

Loss of telephone service, for any reason, would have a negative impact on the GSWSA’s ability to conduct routine daily business.
Loss of telephone service would also prevent customers from being able to telephone GSWSA to conduct business, report water leaks, report water quality problems, report wastewater problems, etc.


      1. CONCEPT of OPERATIONS

GSWSA’s primary internal telephone network is a Mitel system, and most GSWSA telephones and phone numbers function through that system.
GSWSA does have a few telephones and phone numbers that operate outside the Mitel system, but these are still dependent on the external HTC system.
GSWSA maintains and operates approximately 45 cellular telephones, which operate outside of the internal Mitel network and the local HTC system.


      1. EMERGENCY PROCEDURES

Determine whether the problem is in the HTC system or the internal Mitel network.
Ensure priority repairs are put in motion for the appropriate system.

If necessary, gather cell phones to use for outgoing calls. Certain cell phone numbers could be given to key locations, such as the Horry County Police & Fire Dispatch Center, etc.


Consider having HTC redirect our primary business number(s) to cell phone(s).
If appropriate, issue Press Releases with information on how to contact GSWSA while repairs are being made.

Post temporary telephone numbers on the GSWSA website.






SCADA Failure / Cyber-Attack


      1. SITUATION

GSWSA utilizes Supervisory Control and Data Acquisition (SCADA), sometimes referred to as telemetry, throughout the water and wastewater systems.
SCADA is used to monitor a number of parameters at the wastewater lift stations, such as power outage, pump failure, high level in the Wet Well, etc.

SCADA is used to monitor a number of parameters at the wastewater treatment plants, such as power outage, pump failure, high tank/basin level, chlorine leak, etc.


SCADA is used to monitor a number of parameters at the water treatment plant and remote well and/or tank sites, such as power outage, plant shutdown, pump failure, chlorine leak, etc. It is also used to control many aspects of the water plant, including starting / stopping pumps, opening/closing valves, etc.

SCADA is used to monitor and control the rate and volume of supplemental water being provided to other utilities, and to monitor certain water quality parameters.


SCADA monitoring and control signals are transmitted to and from remote sites via an 800 MHz radio system.


      1. THREAT or HAZARD INFORMATION

A failure of the SCADA system would result in a loss of the above remote functionality.
A cyber-attack, or “hacker”, taking control of the SCADA system would give them remote control over many aspects of GSWSA’s water treatment plant and water system.
Another potential scenario involves a physical attack on our facilities being “hidden” by forcing all SCADA conditions to appear normal or preventing an Operator from responding to investigate alarm conditions. This could significantly delay our detection of unauthorized access to or even damage to our facilities.


      1. CONCEPT of OPERATIONS

GSWSA employs several layers of security for remote access to the SCADA system. These include, but are not limited to the following:
In order to make any operational changes through the SCADA system, an ID and password must be correctly entered.


      1. EMERGENCY PROCEDURES


SCADA FAILURE

  • Notify the Technical Services Manger.




  • ISF-13, Electrical and ISF-16, IS will coordinate to ensure priority repairs are put in motion for the appropriate system or components.




  • ISF-9, Water Treatment will modify operational strategies, possibly running pumps in manual mode. Site visits will be required to monitor and/or control remote facilities.




  • ISF-11, Wastewater Treatment will monitor on-site operations more closely.




  • ISF-12, Wastewater Collections will monitor Lift Stations more closely through more frequent site visits as necessary.


CYBER-ATTACK or TAKEOVER

  • Notify the Technical Services Manger.




  • ISF-16, IS and ISF-13, Electrical will coordinate to determine what portion of the system was compromised, and what was accessed.




  • Immediate measures shall be taken to eliminate the threat, up to and including a complete shutdown of the SCADA system if necessary.




  • Report the incident to Safety Manager who will notify Horry County Police and the local Federal Bureau of Investigations (FBI) office. (Threatening or causing harm or damage to a public water utility is a Federal offense.)




  • Safety Manager shall coordinate with law enforcement and with ISF-13 and ISF-16 to ensure appropriate measures are implemented to guard against a repeat event.





IS Failure / Cyber-Attack


      1. SITUATION

GSWSA utilizes computerized Information Technology (IT) / Information Systems (IS) for numerous and widely varied purposes.
GSWSA’s IS / IT systems are connected to “the outside world”, making it susceptible to the threat of unauthorized persons (hackers) gaining access to these systems.


      1. THREAT or HAZARD INFORMATION

IS failure would significantly impact many routine daily functions and operations.
Unauthorized persons gaining access into our IS could potentially obtain critical and highly restricted data.
Unauthorized persons gaining access into our IS could potentially delete, corrupt, or even “steal” critical and highly restricted data.


      1. CONCEPT of OPERATIONS

In order to minimize this threat, GSWSA attempts to limit “outside’ connections to IS / IT systems, maintains Firewall protection, constantly updates virus protection, maintains secure passwords, and restricts physical access to system hardware.


      1. EMERGENCY PROCEDURES


IS / IT SYSTEM FAILURE

  • Notify the IS Manager.




  • ISF-16, IS will ensure priority repairs / corrections are put in motion for the appropriate system.




  • Temporary arrangement may be necessary to allow certain critical operations to continue to function.


CYBER-ATTACK

  • Immediate measures shall be taken to eliminate the threat, up to and including a complete system shutdown if necessary until safeguards can be implemented.




  • Notify the IS Manager.




  • Notify Safety Manager who will notify Horry County Police, and consider notifying the local FBI office.




  • Utilize Backups as necessary to restore lost or corrupted data.




  • Safety Manager shall coordinate with law enforcement and ISF-16 to ensure appropriate measures are implemented to guard against a repeat event.





Major Water Main Leak / Break


      1. SITUATION

GSWSA operates and maintains several hundred miles of water mains throughout its service area.
GSWSA relies on these water mains to transport potable water from the treatment plants to each and every customer, maintaining the same quality, adequate pressure, and volume from start to finish.


      1. THREAT or HAZARD INFORMATION

A broken or leaking water main compromises the water system in a number of ways. Possible complications include, but are not limited to:

  • “lost” water (treated, but not sold)

  • reduction in pressure available to customers

  • reduction in volume (amount) available to customers

  • complete loss of water service to customers

  • loss of business for commercial customers that depend on water service

  • loss of pressure / volume for firefighting activities

  • contamination from foreign materials entering at the leak / break site

  • contamination from foreign materials being back-siphoned into the system through “cross-connections” during low / no pressure situation




      1. CONCEPT of OPERATIONS

GSWSA operates and maintains pressure transmitters at the pumping stations, to control and monitor the pressures that are being introduced into the Distribution System.
GSWSA operates and maintains a number of remote pressure transmitters throughout the Distribution System that, through the SCADA system, constantly monitor the water pressure in many areas of the system.
Any pressure transmitter registering a pre-determined pressure will send a “Low Pressure” alarm to the SCADA System (Control Room PC) and to the On-Call Operator’s pager.


      1. EMERGENCY PROCEDURES

Specific procedures regarding Distribution System maintenance activities are maintained in the Utilities Division Standard Operating Procedure (SOP) Manual.
Determine approximately how many and to what extent are customers are affected.
Classify the incident in accordance with Section 1.6 of the Basic Plan.

Notify Safety Manager for any incident classified as Level 2 or higher.


ISF-23 Taps & Repairs will isolate and repair the leak / break, keeping ISF-5 - Dispatch advised in accordance with departmental SOPs.
ISF-5, Dispatch will issue internal notifications in accordance with departmental SOPs.
ISF-9, Water Treatment may need to adjust pumping rates in some cases.
ISF-14, Laboratory Services will collect follow-up samples as necessary, to ensure no contaminants entered the system during the incident.
ISF-22, Facility Services may be called on to assist with delivery of water to commercial customers as necessary.


      1. FOLLOW-UP

Safety Manager shall conduct a Critique of all incidents classified as Level 2 or higher, and shall properly document and follow-up on all findings and resulting corrective actions and/or recommendations.



Water System Pressure Loss


      1. SITUATION

GSWSA operates and maintains several hundred miles of water mains throughout its service area.
GSWSA relies on these water mains to transport potable water from the treatment plants to each and every customer, maintaining the same quality, adequate pressure, and volume from start to finish.
A partial or total loss of Distribution System pressure could be created by inadequate pressures / volumes being discharged from the pumping stations, and/or, excessive demand for water from the system. (For high system demand due to a major water main leak or break, refer to ESG-11.)


      1. THREAT or HAZARD INFORMATION

A partial or total loss of pressure in the Water Distribution System can create a number of problems. Possible complications include, but are not limited to:

  • reduction in pressure available to customers

  • reduction in volume (amount) available to customers

  • complete loss of water service to customers

  • loss of business for commercial customers that depend on water service

  • loss of pressure / volume for fire fighting activities

  • contamination from foreign materials being back-siphoned into the system through “cross-connections” during low / no pressure




      1. CONCEPT of OPERATIONS

GSWSA operates and maintains pressure transmitters at the pumping stations to control and monitor the pressures that are being introduced into the Distribution System.
GSWSA operates and maintains a number of remote pressure transmitters throughout the Distribution System that, through the SCADA system, constantly monitor the water pressure in many areas of the system.
Any pressure transmitter registering a pre-determined pressure will send a “Low Pressure” alarm to the SCADA System (Control Room PC) and to the On-Call Operator’s pager.


      1. EMERGENCY PROCEDURES

Specific procedures regarding Distribution System maintenance activities are maintained in the Utilities Division Standard Operating Procedure (SOP) Manual.
Determine approximately how many customers are affected, and to what extent. (For assistance estimating how long it will be before dropping water storage levels throughout the system reach “critical”, refer to Action Form 12.)
Classify the incident in accordance with Section 1.6 of the Basic Plan.

Notify Safety Manager for any incident classified as Level 2 or higher.


South Carolina State Primary Drinking Water Regulations, section 61-58.8, subsection C, paragraph (1) reads, “If the pressure in a distribution system or any significant portion of a distribution system should drop to ten (10) pounds per square inch or less the owner or operator of the system shall notify the Department (of Health and Environmental Control – DHEC) immediately.
Any immediate corrective action necessary to protect public health shall take priority over any notification requirement to the Department.”
IF THE CAUSE FOR THE LOSS OF PRESSURE IS UNKNOWN, immediate response efforts shall focus on determining that cause.
IF THE CAUSE IS A MAJOR LEAK OR BREAK, refer to ESG-11.
IF THE CAUSE IS REDUCED PUMPING DUE TO LOW STORAGE LEVELS:

Activate ISF-3, Emergency Communications. Issue Press Releases as appropriate requesting voluntary conservation to reduce system demands.

Coordinate with ISF-9 Water Treatment to increase treated water production and or to redirect flow to the affected area.
Reduce pumping rates to the extent possible, to slow withdrawal from storage tanks and protect emergency reserves. System pressures must be monitored very carefully, to prevent dropping them too far.


      1. FOLLOW-UP

Safety Manager shall conduct a Critique of all incidents classified as Level 2 or higher, and shall properly document and follow-up on all findings and resulting corrective actions and/or recommendations.




Water System Contamination


      1. SITUATION

GSWSA operates and maintains a number of water treatment and storage facilities, as well as a water distribution system consisting of several hundred miles of water mains.


GSWSA relies on these facilities and systems to collect, treat, and transport safe drinking water to each and every customer.
GSWSA’s water treatment, storage and distribution systems are susceptible to contamination in a number of different ways, ranging from accidental and minor to intentional and catastrophic.


      1. THREAT or HAZARD INFORMATION

For the purpose of this procedure, anything other than potable water (completely safe for drinking, and meeting or exceeding all drinking water standards and regulations) entering GSWSA’s water system may be considered “contamination.” Some contaminants may present little or no potential consequences, while others may present extremely high potential consequences.


Some of the possible ways that contaminants could be introduced into the water system include, but are not limited to:

  • draining in while the integrity of the system is compromised due to a leak or break and the subsequent repair operations.

  • being pulled in from back-siphonage during periods of low pressure, such as during major leaks / breaks, system flushing operations, or fire fighting activities.

  • being pushed in from pressurized systems that exceed and overcome our water system pressure.

  • failure or malfunction at a treatment facility resulting in inadequately treated water being distributed to the system.

  • intentional introduction of contaminant in an attempt to cause harm to GSWSA and/or its customers.




      1. CONCEPT of OPERATIONS



Threat Warning: Potential water system contamination events begin with a Threat Warning. Threat Warnings are unusual events, observations, or discoveries that indicate there is a potential contamination incident.
Threat Evaluation: A Threat Warning will typically result in a Threat Evaluation, which is an assessment to determine the credibility of the contamination threat.

Threat Warnings can come from many different sources. The most common forms of Threat Warnings include:

  • Security Breach

  • Witnessed Activity

  • Notification by Perpetrator

  • Notification by Law Enforcement

  • Notification by News Media

  • Notification by Public Health

  • Customer Complaint

  • Unusual Water Quality Readings / Results

Threat Evaluations can progress through up to 3 levels or stages. These are:



  • Possible: A threat is characterized as “possible” if circumstances indicate that there was an opportunity for contamination.




  • Credible: A threat is characterized as “credible” if additional information collected during the investigation supports the Threat Warning and indicates that contamination is likely.




  • Confirmed: A threat is characterized as “confirmed” when definitive information verifies that the water has actually been contaminated. Generally the most reliable confirmation will be analytical results.




      1. PREPAREDNESS / MITIGATION

Security policies and procedures are in effect, and all employees are trained on them, to help ensure the safety and security of all GSWSA facilities, employees, and customers.
Numerous security systems are in place at GSWSA facilities, including burglar alarm systems, security cameras, and high-hazard area intrusion alarms.
Numerous water quality monitoring devices are in place at GSWSA facilities and throughout the distribution system, which will transmit alarms if any monitored parameters exceed allowable limits.
Plant Operators routinely conduct security inspections at all water facilities.
The Laboratory routinely collects and analyzes water quality samples from the water treatment / storage facilities and from sampling points located throughout the distribution system.



      1. RESPONSE



General Response Guidelines




      1. THREAT WARNING RECEIVED or IDENTIFIED

Immediately notify the following personnel:



  • Utilities Division Manager

  • CEO

  • Director of Fleet, Facilities, and Emergency Services

  • Water Transmission Manager

  • Water Treatment Manager

  • Customer Service Supervisor



OBJECTIVE: Attempt to determine whether contamination is “Possible” within ONE HOUR of becoming aware of the Threat Warning. A threat is characterized as “Possible” when circumstances indicate there was an opportunity for contamination. (Obviously, it won’t always be possible to make this determination within this time frame, depending on the exact circumstances and the amount of information available.)
Be extremely careful about what is said over any and all “wireless” communication devices. (Use Radio Code 10-90X in place of the term, “water system contamination”.) All wireless devices can be monitored by persons with scanners. This includes radios and cell phones. Conversations are much more likely to be “overheard” when using the 800 MHz two-way radio system.
If the Threat Warning is associated with one or more water treatment or storage facilities, Water Operators will be immediately dispatched to investigate and evaluate the site(s) in question. Consider isolating the facility in question if it will not unnecessarily and negatively affect GSWSA customers.
If the Threat Warning is associated with a particular area of the water distribution system, Water System Operators will be immediately dispatched to investigate and evaluate the site(s) in question.
If the Threat Warning cannot be associated with any particular area, Water Operators should still be dispatched to conduct thorough security inspections of all water treatment and storage facilities. Laboratory Services personnel should be placed on stand-by for possible response to the distribution system.
The Laboratory should begin developing a sampling strategy, based on whatever information is available at the time.
Complete a “Contamination Threat Evaluation” worksheet, which can be found in the Action Forms 13 section.


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