Sanitary sewer overflows (SSOs) can present major problems for communities—they can be costly to fix, create public health issues, and attract regulatory attention, any one of which can take significant time and resources to address. In many cases, though, SSOs aren’t 100% avoidable, making an emergency response plan critical to lessening the consequences when one of these events does occur.
A practical, up-to-date emergency response plan is a key component in a proactive asset management strategy, and it allows utilities to ensure everyone knows exactly what to do during a crisis. Without it, you rely on the instincts and in-the-moment reactions of staff, which can be costly and unsafe when action needs to be taken quickly. Having created several of these plans for the communities we work with, we have the planning process down to something of a science. Using these three steps, you can create a plan for your utility’s employees that defines standard operating procedures to follow in the event of an SSO, taking the guesswork out of the response.
Step 0: Know your assets
Before you respond to an SSO, it is important that you know where you are going and what you own. My previous post on off-street assets and easements is a good place to start.
Step 1: Prepare your team
You’ll first want to define who needs to be directly involved in an emergency response effort. The team you choose should be ready to mobilize in the case of an SSO at any time and needs to be familiar with the procedures laid out in your plan so they can carry them out effectively. It’s also wise to prepare members of your department staff to fill multiple roles on the response team, such as safety officer or resource officer. At the very least, each member of the staff should be trained in assisting with containing and stopping the overflow in the event of an all-hands-on-deck crisis. Document who has been trained for each role along with their contact information and keep an additional list of outside contractors and consulting engineers that can be called upon for extra assistance if necessary.
In addition to understanding these roles, a major part of preparing your team is ensuring they’re capable of carrying out necessary emergency response procedures safely. This means they’ll need to have up-to-date safety training in areas like confined space procedures, bloodborne pathogens, and first aid, as well as the right equipment. Standard personal protection equipment (PPE) (e.g. traffic vests, sharps-proof gloves, safety glasses) and communication, cleaning, bypass pumping, and site safety equipment, among other types, are essential if the team hopes to be effective in their response. Don’t forget to inspect your equipment quarterly or on a basis suggested by the manufacturer and replace anything that’s damaged, missing, or expired.
Step 2: Define field procedures
When an SSO occurs, there are three main things that need to be done: assess the situation and secure the site, contain and stop the overflow, and clean up. While the specific steps within those objectives might seem obvious to someone with a lot of experience in taking care of SSOs, remember that staff are coming from a variety of experience levels and backgrounds. They may have been trained to achieve these goals in a different way than you’d like them to or may not have first-hand experience dealing with an overflow.
In this section of the plan, you’ll likely need to be more specific than you might think necessary, but this is important if you want your plan to be actionable. Here’s an example of how specific one step in the “contain and stop the overflow” process might be: “If it is apparent that the SSO cannot be stopped or contained quickly, set up pump equipment and hoses from the upstream manhole to the nearest flowing manhole below the blockage. Use a vac truck to remove as much sewage as possible until pumping is established.”
Step 3: Check reporting requirements
The requirements for reporting an SSO will differ substantially depending on where your utility is located. Because the EPA needs to be notified within 24 hours of an SSO, and your state regulatory agency may also need to be notified very promptly, you want to be aware of your obligations well before an overflow occurs. Implementing an SSO reporting tool can help simplify the recordkeeping and reporting process. For instance, one of our clients uses a tool that automatically emails the Water and Sewer Commissioner within minutes of the field supervisor inputting SSO data from their tablet in the field. The commissioner can then use the tool to review data, generate the necessary reports, and electronically submit the required notifications. If using one of these tools, include detailed instructions for it in your emergency response plan as well.
Developing a comprehensive emergency response plan can feel like a huge accomplishment (and it should), but your work isn’t done when you hit print on your document. These plans should be updated regularly. After any SSO event, you’ll want to conduct a debrief with your team to see what could be improved for the next response and incorporate those improvements in your procedures. In addition, at least once a year, your department should review the plan to address any changes in staffing, contact information, reporting requirements, or training needs. All of this ensures your team is always prepared for an emergency and can reliably protect the safety of the public and environment while hopefully preventing recurring SSOs.
