Drinking Water Quality Incident Response and Reporting Plan · Drinking Water Quality Incident...

Drinking Water Quality Incident Response and Reporting Plan

July 2019TRIM: 19/2008


17NS18-REC-19-103-1.0 i TRIM: 19/2008July 2019

ContentsAcronyms and Abbreviations ...........................................................................................................1

1. Introduction....................................................................................................................................2

2. Purpose ............................................................................................................................................2

3. Scope .................................................................................................................................................2

4. Responses and Reporting...........................................................................................................2

5. Response Protocols ......................................................................................................................95.1. Communication...............................................................................................................................95.2. Equipment and Systems..................................................................................................................9

6. Emergency Contacts ..................................................................................................................10

7. Records ..........................................................................................................................................11

8. Investigation / De-brief / Improvements ..........................................................................11

9. Staff Training ...............................................................................................................................12

10. Review........................................................................................................................................12

11. References ................................................................................................................................13

AppendicesManaging Pathogen Risk in Drinking Water Response Protocol ............................................................................................14Chemical or Physical Parameter above ADWG Guideline Value..............................................................................................15Fluoride Overdose Plan .............................................................................................................................................................................16Boil Water Alert Template .......................................................................................................................................................................17


17NS18-REC-19-103-1.0 ii TRIM: 19/2008July 2019

Document History and StatusRevision Date Reviewed by Initials Details

0.1 13 May 19 Tasleem Hasan TH Incorporates initial comments / feedback from local PHU and Council on the incident response SOP that was developed. Document will be called a Plan.

0.2 14 June 196 June 19

Kerryn Lawrence, PHU Kempsey Shire Council

KLKSC

PHU feedback.Client review.

0.3 17 June 19 Tasleem Hasan TH Final issued to client, incorporating comments and feedback.

1.0 3 July 19 Kerryn Lawrence, PHU Kempsey Shire Council

KL, KSC

Final approved for submission to Council for adoption

Author: Tasleem Hasan

Project manager: Tasleem Hasan, Viridis Consultants Pty Ltd

Name of client: Kempsey Shire Council

Name of document: Drinking Water Quality Incident Response and Reporting Plan

Document number REC-19-103

Document version: 1.0

Project number: 17NS18


17NS18-REC-19-103-1.0 1 TRIM: 19/2008July 2019

Acronyms and Abbreviations

Acronym Detail

ADWG Australian Drinking Water Guidelines

BCP Local Business Continuity Plan

BWA Boil Water Alert

CCP Critical Control Point

DMP Drought Management Plan

DoI Department of Industry Water

DWMS Drinking Water Management System

EMP Emergency Management Plan

FASS Forensic and Analytical Science Services

KSC Kempsey Shire Council

LEMO Local Emergency Management Officer

PHU Public Health Unit

SCADA Supervisory Control and Data Acquisition

SOP Standard Operating Procedure

TL Team Leader

WTP Water Treatment Plant

WQ Water Quality


17NS18-REC-19-103-1.0 2 TRIM: 19/2008July 2019

1. Introduction

Kempsey Shire Council (KSC or Council) has developed a Drinking Water Management System (DWMS) with the goal of protecting public health through the provision of safe drinking water. Drinking water quality incident management is an essential part of the DWMS.

Considered and controlled responses to incidents and emergencies that can compromise the safety of water quality are essential for protecting public health, as well as maintaining consumer confidence and the organisation’s reputation.

Although preventive strategies are intended to prevent incidents and emergency situations from occurring, incidents can still occur. In these cases, it is essential to respond constructively and efficiently to prevent the risk from compromised water quality to consumers.

The benefits of establishing and implementing an incident response plan include:

timely response to drinking water incidents and emergencies reduced health risks by preventing or reducing the exposure of customers to poor water quality clearly defined roles and responsibilities of employees and stakeholders consistency in response improved audit trail

2. Purpose

The purpose of this Plan is to describe the process for drinking water quality incident response (investigation and protocols), reporting and records requirements for Council.

3. Scope

This Plan applies to Council’s response to drinking water quality incidents in relation to public health. It does not include management of water quantity, nor does it include specific details on natural disaster or emergency management, which could impact water quality.

Other related plans/protocols exist for these situations, for example, through Council’s Local Business Continuity Plan (BCP), Drought Management Plan (DMP) and Emergency Management Plan (EMP). These would include things such as flood response and prolonged supply disruption that may include water quality issues.

4. Responses and Reporting

The Tables in this Section outline the key drinking water quality incident levels/types, responsibility for managing incident, communication, response (investigation and corrective actions), records and reporting requirements. In short, the levels are:

1. Operational – managed in-house and external reporting to the NSW Health local Public Health Unit (PHU) is not required

2. Event – managed in-house but some additional coordination or external advice/consultation may be required. External reporting to local PHU is not required, but may be, deemed appropriate or necessary, for example, if the issue is widespread in the reticulation or unusual.

3. Incident – managed in-house with coordination and external advice/consultation. External reporting to local PHU is obligatory.


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4. Emergency – coordinated response and managed through the BCP, DMP, EMP or SMDESP, as relevant.

The generic framework for incident response and management includes:

Identify and Assess – identify the incident type and level, review water quality data, assess risks, isolate and contain, as possible

Communicate – inform relevant internal staff, notify external stakeholders as relevant, including the regulator and customers

Investigate and Rectify – determine cause/s, undertake corrective actions, review water quality data, document actions undertaken

Improve – de-brief, identify learnings from the incident, review and improvements and report


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Incident Level Description Key relevant incidents

Who identifies?

Who manages?

Response Actions or Protocols

RecordsNotification

to PHU required?

Inform/consult other external stakeholders?

Who will notify PHU?

Out-of-spec (target) result for operational parameters (as per respective Subplans)

Operators Operators (& TL)

Respective SOP or as per respective DWMS Subplan

WQ data spreadsheet / Plant diary

As deemed relevant No

Process Engineer, Manager or Delegate

Ordinary operational issues at the plant (e.g. with pumps, instruments)

Operators Operators (& TL)

Operator knowledge and respective SOP

Plant diary or as per SOP No No NA

Ordinary operational issues in the reticulation (e.g. pipe breaks, repairs)

Maintenance crew or Customer Service (complaints)

Relevant Operational Team (& relevant TL)

Respective SOP As per SOP No No NA

1.Operational

There is no non-compliance against the ADWG health-based guideline values to impact public health. Matter is managed within the water team in line with the DWMS documents.

Customer complaints (few scattered with no health risk or implication)

Customer Service (complaints) / Process Engineer

TL and relevant Operational Team

Follow the respective complaints management process.

IT Vision Platform No No NA


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Who identifies?

Who manages?


RecordsNotification

to PHU required?



Alert limit breach for CCPs (includes reservoirs)

Operators Operators & TL

Follow the respective CCP Procedure

Initial Incident Report Form and Incident Database, Form 5 for fluoride

As deemed relevant

DoI, if relevant to discuss any operational issues.


Fluoridation issue:

- failure to fluoridate for >24 hours- plant out of operation for repair/maintenance

Underdose and overdose is captured as a CCP


Investigate and rectify, fill in Form 5, inform NSW Health.

Form 5

Submit Form 5 to the Water Unit, NSW Health and copy to local PHU.

DoI, if relevant to discuss any operational issues.

NA

Algal bloom in SM Dam

Operators and Water Quality Officer

Operators & TL

Follow the Dam Algae Monitoring Plan

Initial Incident Report Form and Incident Database

As deemed relevant

As deemed relevant


2.Event

Heightened level of alert as there may be an adverse effect on public health, if not managed adequately, or a reporting requirement. Issue is managed within the water team but may require consultation with or advice from local PHU and/or DoI.

Raw water quality problem or contamination (e.g. chemical or oil spill or any significant issue highlighted)


Assess any impact on the dosing plant / WTP and need for further actions. Refer also to NSW Health protocol - pathogens (Appendix A)

Plant diary / Initial Incident Report Form and Incident Database

As deemed relevant

As deemed relevant

Process Engineer Manager or Delegate


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Who identifies?

Who manages?


RecordsNotification

to PHU required?



Total coliform detection in reticulation

Laboratory / Water Quality Officer

TL & relevant Operational Team

NSW Health protocol - pathogens (Appendix A)

Email notification FASS / NSW Health Drinking Water Database

Yes As deemed relevant.


Issue with reservoirs (e.g. security breach and vandalism).

Operators TL (& Operators)

Assess any impact on the water quality and need for further actions.

Initial Incident Report Form and Incident Database if major issue

As deemed relevant

As deemed relevant


Low chlorine (<0.2 mg/L) in reticulation

Laboratory / Water Quality Officer / Operators


Check upstream processes and CCPs, check reservoir integrity, flushing if required.

WQ data spreadsheet / Initial Incident Report Form and Incident Database if widespread.

As deemed relevant

As deemed relevant.


Non–compliance against ADWG aesthetic-based guidelines values (results from samples tested in the external laboratory) during routine verification monitoring



NSW Health protocols - physical and chemical (Appendix B)


Yes As deemed relevant.



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Who identifies?

Who manages?


RecordsNotification

to PHU required?



Customer complaints (widespread, suspected health risk or implication)

Customer Service (complaints) / Process Engineer

TL and relevant Operational Team

Follow the respective complaints management process.

IT Vision Platform Yes. As deemed

relevant.



17NS18-REC-19-103-1.0 7 TRIM: 19/2008July 2019


Who identifies?

Who manages?


RecordsNotification

to PHU required?



Critical limit breach for the CCPs (includes reservoirs integrity).

Operators TL (& Operators)

Follow the respective CCP, Refer also to NSW Health protocol -pathogens (Appendix A)

Initial Incident Report Form and Incident Database.

Yes

DoI, as needed.

Other stakeholders deemed relevant


E. coli detection in reticulation.



NSW Health protocol - pathogens (Appendix A)


Yes

DoI, as needed.



3. Water Quality

Incident

High potential for water quality risk. Event is managed within the water team responsible but in some cases, it may require coordination across Council sections and resources, and external support/advice such as from PHU and DoI.

Non-compliance against ADWG health-based guideline values (results from samples tested in the external laboratory) during routine verification monitoring


TL (& relevant Operational Team)

NSW Health protocols - chemicals (Appendix B)

Email notification FASS / NSW Health Drinking Water Database.

Yes

DoI, as needed.




17NS18-REC-19-103-1.0 8 TRIM: 19/2008July 2019


Who identifies?

Who manages?


RecordsNotification

to PHU required?



Natural disaster (flooding, drought, major storm, fire)

Outbreak of waterborne disease (suspected or confirmed linked to water supply)

4.Emergency

Declared emergency situation by local stakeholders.Requires coordination across Council and is likely to require external resourcing and support from agencies, such as PHU, DoI, emergency responders e.g. NSW RFS, SES.

Prolonged power outage causing quantity and quality problems.

Complete failure of system/s

Council in discussion with stakeholders

Council wide response – Local Emergency Management Officer (LEMO)

BCP / DMP / EMP

As per the respective Plan

YesYes - all relevant stakeholders

Manager

Note: a review of the BCP and EMP will be undertaken by KSC in due course to ensure that detailed response protocols/actions are available for Level 4 in relation to water quality.


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5. Response Protocols

The response protocols used by Council for the management of drinking water quality incidents include:

Managing pathogen risk in drinking water response protocol (Appendix A), NSW Health protocol Detection of chemical parameter above ADWG guideline value (Appendix B), NSW Health protocol adapted Fluoride overdose plan (Appendix C), Fluoride Code Alert level framework for management of cyanobacteria in drinking water (Appendix D), WQRA, Report 74

protocol adapted

Additional reference documentation that provides suggestions on actions to take, investigations and items to consider for managing the risks of pathogens in drinking water is available at:

https://www.health.nsw.gov.au/environment/water/Documents/response-protocol-micro-q.pdf

Further information regarding NSW Health protocols is available at:

https://www.health.nsw.gov.au/environment/water/Pages/drinking-water-quality-and-incidents.aspx

5.1. Communication

During an incident, the General Manager or delegate will manage communication to the customer and external media, if the need arises.

The Manager of Water and Sewer is responsible for leading a coordinated approach to communications during an incident response by establishing an Incident Response Team. This will include involvement from Council’s water process management team, Council’s media/communications team and other relevant Council staff and stakeholders, including administration officer support for minute taking to ensure that all parties are aware of actions, updates and responses. This may include the Incident Response Team attending structured daily meetings, dependent on the nature of the incident.

The Manager Water and Sewer will consult with the local PHU and/ DoI to determine need for customer notification and the content of notices such as ‘boil water alert (BWA)’, ‘do not drink water’ etc.

A draft boil water alert template which Council may use and distribute to its customers, post on notice boards, website, social media etc., is attached as Appendix E. The BWA, if issued, will be determined, designed, instigated and lifted in consultation with the local PHU.

Further guidance on boil water alerts (including need, issue and lifting) is available at:

https://www.health.nsw.gov.au/environment/water/Pages/Boil-water-alert-guidance.aspx

5.2. Equipment and Systems

The Process Engineer or Manager Water and Sewer will ensure that the Incident Response team/s has the access to the required equipment and systems to manage an incident, as necessary and when necessary will establish and set up a control center in the Training Centre, Thompson Street, West Kempsey.

A variety of equipment and methods are used to communicate information about a drinking water incident within the Incident Response team, as well as stakeholders. Standard equipment and methods are part of Council’s normal facilities and procedures (e.g. office space, mobile telephone for field, remote and out of hours contact, landline telephone, email, Skype, vehicles and testing equipment) and these are available for use by the Incident Response team.

Other systems that are used during an incident include the water quality operational spreadsheets (WaterOutlook in future), SCADA (can be accessed remotely) and the Incident Database. These are


https://www.health.nsw.gov.au/environment/water/Pages/drinking-water-quality-and-incidents.aspx



17NS18-REC-19-103-1.0 10 TRIM: 19/2008July 2019

available on Councils’ records management system and are electronically available on the local network folder (F:Drive) for use by the response team.

6. Emergency ContactsThe key relevant external contacts in relation to drinking water quality incidents are listed in the Table below.

A broader group of emergency contacts including aged care, pre-school, childcare, schools and hospitals will be developed by Council (part of the DWMS Improvement Plan) and maintained as a separate list on Councils’ records management system and will be electronically available on the local network folder (F:Drive).

The details in the Table below is kept updated by the Water Quality Officer, reviewed annually when the DWMS Annual Report is prepared and updated if required.

Organisation Name / Position Contact Details North Coast PHU Kerryn Lawrence, Senior

Environmental Health Officer

P: 02 6589 2108 D: 02 6589 2143 M: 0418 112 248 E: [email protected]

North Coast PHU Afterhours, Environmental Health Officer

M: 0428 882 805

Water Unit, NSW Health

NA P: 02 9391 9993E: [email protected]

DoI Glenn George, Regional Manager Urban Water

P: 02 6653 0127 M: 0411 449 745 E: [email protected]

DoI Graham Campbell, Regional Inspector

P: 02 4904 2517 M: 0419620990 E: [email protected]

DoI Geoff Snell, Senior Project Officer P: 02 6650 3127M: 0417 470 250E: [email protected]

Kempsey Local Aboriginal Land Council

Greg Douglas, CEO P: 02 6562 8971P: 02 6562 8688E: [email protected]

NSW Aboriginal Land Council

Trent Lynwood P: 02 6659 1200 M: 0400 563 018

Thungutti Local Aboriginal Land Council

Richard Campbell, CEO P: 02 6659 1200 M: 0400 563 018

mailto:[email protected]







17NS18-REC-19-103-1.0 11 TRIM: 19/2008July 2019

7. Records

Maintaining records for the management of incidents is very important. It provides the necessary information during the review of the DWMS, acts as evidence during audits, provides a platform for continuous improvement and overall is good management practice.

The position responsible for managing the Incident and the records to be utilized and captured are outlined in the Tables in Section 4. The responsibility for managing the incident includes maintaining of records. The range of incident records include the Initial Incident Report Form (separate supporting form), Form 5 for fluoridation, water quality data spreadsheets and plant diary (and WaterOutlook in the future).

Form 5 is included in the New South Wales Code of Practice for Fluoridation of Public Water Supplies (Appendix C of the Code). The current copy of the Code is available at:

https://www.health.nsw.gov.au/environment/water/Documents/code-of-practice.pdf

For incidents which are recorded in the Initial Incident Report Form and Incident Database (Level 2 Incidents which are widespread and/or as deemed necessary and Level 3 – refer to Tables in Section 4), supporting information or evidence may be collected during the incident, for example, photographs, follow up samples, external communication emails and logs. These should be recorded and maintained in the respective incident logfile on the local network folder (F:Drive) by the Incident Response team (i.e. person/s managing the incident and person externally reporting the incident).

Documentation for investigations regarding water quality incidents and emergencies are stored as year folders, file path is:

F:\UTILITIES\DRAFT New Water Services\DWMS\E6 - Incident Management\6.2 Incident Response

8. Investigation / De-brief / Improvements

An investigation is conducted, whenever an Incident Level 1 or 2 occurs (refer to Tables in Section 4) which includes a toolbox meeting to discuss findings, issues and corrective measures. A de-brief is conducted post investigation whenever an Incident Level 3 or 4 occurs (refer to Tables in Section 4) which includes a formal meeting and report.

Investigations and de-briefs into the Drinking Water Incident Levels ensure lessons from an incident are documented and actions that will prevent a recurrence or improve the response for similar situations are completed.

The outcomes of the investigation and de-briefs are documented in the Monthly Water Quality Report and Annual Water Quality Report.

The Process Engineer or Manager Water and Sewer is responsible for facilitating or nominating a facilitator to conduct the de-brief, ensuring the outcomes are documented and actions implemented. Outcomes of a de-brief may include a review of this document, updating the DWMS Risk Register or updating the DWMS Continuous Improvement Plan.

Guidance from NSW Health for incident de-brief is reproduced in Box 1. Also refer to:


https://www.health.nsw.gov.au/environment/water/Documents/code-of-practice.pdf



17NS18-REC-19-103-1.0 12 TRIM: 19/2008July 2019

Box 1: Incident de-brief and reporting guidance from NSW Health

Directly following completion of the incident response, arrange a debrief discussion with relevant stakeholders, including all staff involved, NSW Health and DoI. The debrief should allow stakeholders to discuss the incident and address any issues or concerns. The aim of the debrief is to allow the utility, NSW Health and DoI to learn from the incident and improve operations and responses.

The debrief discussion should be followed up with a written summary report on the incident considering factors such as:

the cause of the problem how the problem was first identified the most critical actions and pieces of information required to respond challenges in communication and how were they addressed how well the protocol was followed any necessary improvements to equipment, processes, SOPs or the incident management plan documentation of relevant information during the incident any actions to improve preparedness and planning for future incidents.

Utilities should consider the need to support staff who may feel a significant burden of responsibility for an incident (e.g. through counselling or an employee assistance program).

9. Staff Training

Incident response training is essential for the effective implementation of these protocols. Training educates and familiarises staff and contractors about incident (and emergency) situations, resulting effects on water systems and response protocols. It also provides an opportunity to practice responses.

A mock drinking water incident training exercise is to be held every two (2) years if no incident has occurred in that period to ensure the communication and coordination is functioning as outlined. A report of training is to be kept to reflect the training history, including refreshers, as evidence.

10. Review

This document is reviewed in detail every two years at an annual DWQMS review meeting. Other earlier triggers for review include:

when de-brief meeting outcomes following an incident or emergency recommend a review of the document where updates or revisions of the DWMS occur that, may impact the incident management processes as

described in this document immediately upon change in roles and responsibilities of pertinent Council staff.

The Process Engineer or Manager Water and Sewer is responsible for facilitating the review of this document.


17NS18-REC-19-103-1.0 13 TRIM: 19/2008July 2019

11. References

Department of Health. (2003). Emergency Response Planning Guide for Public Drinking Water Systems. Division of Drinking Water, Washington State Department of Health.

NSW Health. (2018). New South Wales Code of Practice for Fluoridation of Public Water Supplies. Fluoridation of Public Water Supplies Act 1957.

NHMRC & NRMMC. (2011). National Water Quality Management Strategy: Australian Drinking Water Guidelines. 6th Ed., 3.4. National Health and Medical Research Council and Natural Resource Management Ministerial Council. Australian Government. Canberra.

NSW Health website. Drinking Water. Date accessed: 3 April 2019. http://www.health.nsw.gov.au/environment/water/Pages/Drinking-Water-Quality-and-Incidents.aspx


WQRA (2010) Report 74 – Management Strategies for Cyanobacteria: A guide for Water Utilities. Water Research Australia.

http://www.health.nsw.gov.au/environment/water/Pages/Drinking-Water-Quality-and-Incidents.aspx



17NS18-REC-19-103-1.0 14 TRIM: 19/2008July 2019

Appendix AManaging Pathogen Risk in Drinking Water Response Protocol


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Appendix BChemical or Physical Parameter above ADWG Guideline Value

Physical or Chemical Characteristic(s) Exceed a Guideline Value

Investigate treatment process and possible sources of contamination. Consult local PHU and DoI Water

regional inspector.AND

Resample at same site upon advice from the local PHU.

Does the risk assessment indicate

an ongoing risk?

Consult with local PHU and DPI Water regional inspector regarding rectification, alternative supply, and/or warning. PHU will consult with the Water Unit.

YES

Resume normal sampling

Use available data to assess risk.

Resume normal sampling

NO

YES

NO

Contact patients on dialysis

machine register

NO

YES

NO

CHECK

Does the resample meet the guideline

value?

Could there be an acute health effect?

Does chlorine exceed the ADWG

value?

NO

YES


17NS18-REC-19-103-1.0 16 TRIM: 19/2008July 2019

Appendix CFluoride Overdose Plan


17NS18-REC-19-103-1.0 17 TRIM: 19/2008July 2019

Appendix DAlert Level Framework for Management of Cyanobacteria in Drinking Water


17NS18-REC-19-103-1.0 18 TRIM: 19/2008July 2019

Appendix EBoil Water Alert Template

*DATE*

Kempsey Shire Council: *Supply system name* Boil Water Alert

Where E. coli is detected and an issue/risk has been identified in consultation with the local PHU:

Regular monitoring for E. coli bacteria in the water supply system is conducted by Council. Recent monitoring has shown E. coli to be present in the *Supply system name*.

Detection of E. coli bacteria mean that drinking water in the *Supply system name* is unsafe.

E. coli in drinking water shows that the water may be contaminated with faeces and organisms that may cause gastrointestinal illness.

Where a CCP critical limit is breached (e.g. due to poor raw water quality or treatment failure) and an issue/risk has been identified in consultation with the local PHU:

Ongoing monitoring of critical processes in the water supply system is conducted by Council.

Recent conditions *[describe conditions e.g. flood]* have caused problems with water treatment making drinking water in the *Supply system name* unsafe.

OR

Problems with water treatment mean that drinking water in the *Supply system name* is unsafe.

In consultation with NSW Health, you are advised that water used for drinking or food preparation should be brought to a rolling boil to make it safe. Kettles with automatic shut off switches can do this. Water should then be allowed to cool and stored in a clean container with a lid and refrigerated.

Bottled or cooled boiled water should be used for:

Drinking

Washing uncooked food (e.g. salad, vegetables and fruit)

Making ice

Cleaning teeth

Gargling

Pet’s drinking water

Dishes should be washed in hot soapy water or in a dishwasher.

Children should take bottled or cooled boiled water to school.

Council is working to fix the problem.

This advice should be followed until further notice.

Please share this information with other people who drink this water, especially anyone who may not get this notice directly. For further information, visit Council office or contact Council on (02) 6566 3200.

www.viridis.net.au

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