What is Contingency Planning
Groundwater contamination can strike any community at any time. Faulty or corroded hazardous material storage units, fires, shipping and handling accidents, human error, product mismanagement and in some cases, intentional illegal dumping of hazardous materials all can result in groundwater contamination despite the variety of regulatory and non-regulatory preventative measures instituted under the Source Water Protection Program (SWPP).
WHPP CONTINGENCY PLANNING IN THE HAMILTON TO NEW BALTIMORE AREA
The Hamilton to New Baltimore Groundwater Consortium’s SWPP Contingency Plan addresses contingency planning for both incident-related releases (IRRs), i.e., those hazardous materials releases associated with an accident, and releases detected through a monitoring well. The primary objective of the plan is to ensure that the Consortium is informed of and kept up to date on the status of hazardous material releases in the Source Water Protection Areas. By including the Consortium in the notification/information loops, the Consortium can evaluate the specific nature of a release; remediation activities; and the potential for long-term groundwater quality impacts. Secondary objectives include tracking the occurrence of regulated substance releases in the SWPAs, spill prevention awareness, and general groundwater education for area fire departments.
The Consortium’s Contingency Plan is based around three main components: notification to the Groundwater Consortium Manager (GCM), submission of release information, and incident assessment.
Notification of the Groundwater Consortium Manager (GCM)
Not all releases in a SWPA require notification to the Groundwater Consortium Manager. Only those releases which:
- Contact a pervious ground surface; or
- Enter a surface water body; or
- Enter a dry well or storm sewer; and which
- Is not immediately and completely remediated within (24) hours
are required to be reported to the GCM. Notifying the GCM does not alleviate the responsible party’s obligation to contact other federal, state, and local emergency response agencies.
Submission of Release Information
When a facility operator contacts the GCM to report a release, the facility operator must provide general information on facility location, the nature of the release, material(s) released, and estimated volume of the release. This information will be logged onto a Regulated Substance Release Notice (RSRN) form. Within seventy-two (72) hours of the release, the facility operator also will submit, via phone or fax, a Preliminary Release Report (PRR) containing additional and/or revised information on the release and response actions taken.
Incident Assessment- The Incident Management Assessment Team
Any release in a SWPA is subject to review and assessment by an Incident Management Assessment Team (IMAT) to determine if any or additional follow-up action needs to be taken by the Consortium. Representatives from the Consortium serve as the primary IMAT members.Other members, where applicable, include Consortium lab directors; responding fire department personnel; local/state emergency management agency representatives; and/or any other technical expert(s) needed for a complete assessment of the release.
A determination of what additional follow-up work may be needed is based on consideration of a variety of factors, including location of release, site of detection and nature of the material.