Texas Emergency Preparedness & Water-System Resiliency

Texas public water systems must be prepared to continue essential water service during emergencies such as extended power outages, severe weather, hurricanes, floods, freezes, equipment failures, and other events that can interrupt normal operations. The Texas Commission on Environmental Quality, or TCEQ, regulates important emergency-preparedness requirements through 30 TAC Chapter 290 and related provisions of the Texas Water Code.

For operators, resiliency means more than having an emergency plan stored in an office. The system must be able to respond to actual operating conditions, maintain critical functions, communicate effectively, protect water quality, and restore normal service safely.

Emergency Preparedness Plan

An Emergency Preparedness Plan, or EPP, describes how an affected utility will maintain water service during an extended power outage and other emergency conditions.

The plan includes information such as:

• system facilities;
• emergency contacts;
• emergency power strategy;
• pressure-maintenance strategy;
• critical equipment;
• response procedures;
• implementation responsibilities.

What Is an Affected Utility?

Texas emergency-preparedness rules use the term affected utility for water-service providers that meet the applicable statutory definition.

TCEQ currently identifies affected systems as those that furnish water to more than one customer and serve residential customers or provide overnight accommodations.

Examples of Affected Utilities

Examples can include:

• public water systems with residential customers;
• hospitals;
• assisted-living facilities;
• nursing homes;
• prisons and detention centers with overnight occupancy;
• hotels and motels;
• resorts;
• universities or boarding schools with dormitories;
• RV parks;
• recreation areas with overnight camping;
• other systems serving overnight populations.

Systems That May Not Be Affected Utilities

A noncommunity system without overnight accommodations generally does not fall within the affected-utility requirement solely because it is a public water system.

Examples can include:

• schools without dormitories;
• daycare centers without overnight service;
• restaurants;
• industrial facilities;
• office buildings;
• banks;
• churches without overnight accommodations.

Do Not Assume Every PWS Has the Same EPP Requirement

The operator should determine whether the system meets the current TCEQ definition of an affected utility.

Public water system status and affected-utility status are related but not identical concepts.

Why an EPP Is Required

Texas emergency-preparedness requirements are designed to ensure that affected utilities can continue providing water during extended electrical outages.

The system must demonstrate a practical method of maintaining required distribution pressure during the emergency period.

Extended Power Outage

The Texas EPP requirements specifically address power outages lasting:

24 hours or more

following an emergency or natural disaster.

Pressure Requirement Outside Harris and Fort Bend Counties

For affected utilities located outside Harris and Fort Bend Counties, current Texas requirements generally require the system to maintain at least:

20 psi

during an extended power outage, or another pressure approved by the executive director where applicable.

Pressure Requirement in Harris and Fort Bend Counties

Affected utilities in Harris and Fort Bend Counties are subject to a higher emergency-pressure requirement.

The required minimum is:

35 psi

during the applicable extended power outage condition.

Normal Pressure and Emergency Pressure Are Different Concepts

Operators should distinguish between:

• normal distribution-system pressure requirements;
• special minimum emergency-pressure requirements under the EPP rules.

The emergency threshold does not replace normal operating requirements.

EPP Approval

An affected utility must submit an Emergency Preparedness Plan to TCEQ for review and approval.

The plan must demonstrate how the system will meet the applicable emergency-operation requirements.

New Systems

A new affected utility must obtain the required EPP approval before beginning water service when the applicable Texas rules require it.

The Plan Must Reflect the Actual System

An EPP should describe the real facilities and capabilities of the system.

The plan should correspond to:

• actual wells;
• surface-water facilities;
• treatment plants;
• pump stations;
• storage facilities;
• pressure facilities;
• emergency power equipment.

EPP Is Not Just a Paper Exercise

Once approved, the affected utility must implement the plan and maintain the equipment necessary to carry it out.

A generator listed in an EPP is not useful if it:

• does not start;
• has no fuel;
• cannot supply the required load;
• is not connected correctly;
• has not been maintained.

Emergency Power

Emergency power is one of the major components of water-system resiliency.

Critical equipment can include:

• well pumps;
• raw-water pumps;
• high-service pumps;
• booster pumps;
• treatment equipment;
• chemical-feed equipment;
• controls;
• communications;
• other facilities necessary to maintain service.

Generators

Generators are a common emergency-power option.

Operators should know:

• generator capacity;
• which equipment is connected;
• starting procedure;
• fuel type;
• fuel supply;
• runtime limitations;
• maintenance requirements;
• testing schedule.

Automatic Starting Equipment

Some affected utilities are required to use automatically starting auxiliary generation at critical facilities.

Operators should understand whether emergency equipment starts:

• automatically;
• manually;
• through a transfer switch;
• through another approved arrangement.

Test Emergency Equipment

Emergency equipment should be tested under realistic conditions.

A useful test can verify:

• startup;
• transfer;
• load capability;
• fuel supply;
• alarms;
• return to normal power.

Fuel Planning

A generator cannot provide resiliency without an adequate fuel strategy.

Operators should consider:

• fuel storage capacity;
• estimated consumption;
• delivery arrangements;
• access during severe weather;
• fuel quality;
• safe storage.

Example Fuel Calculation

Assume an emergency generator consumes 8 gallons of diesel per hour and must operate for 24 hours.

Fuel required = 8 gal/hr × 24 hr

Fuel required = 192 gallons

This is the theoretical operating requirement. A real emergency plan should also consider reserve fuel, testing, startup, and uncertainty in actual load.

Storage as an Emergency Strategy

Stored water can support emergency operation, but operators must understand how the stored water reaches customers.

Ground storage may still require pumps and electricity.

Elevated storage can provide pressure through elevation when properly configured.

Pressure from Elevation

Water elevation creates hydrostatic pressure.

A commonly used approximation is:

Pressure, psi = 0.433 × elevation difference, ft

Example

If the water surface is 70 feet above a service connection:

Pressure = 0.433 × 70

Pressure = 30.3 psi

The operator should remember that actual system pressure also depends on friction loss, water level, demand, and system configuration.

Emergency Interconnections

An approved emergency strategy can involve an interconnection with another water system.

Operators should know:

• location of the interconnection;
• valve arrangement;
• available pressure;
• available flow;
• water-quality compatibility;
• communication procedures.

Do Not Discover the Interconnection During the Emergency

Emergency interconnections should be understood and maintained before they are needed.

Potential problems include:

• inoperable valves;
• inadequate pressure;
• unknown capacity;
• cross-connection concerns;
• lack of operational coordination.

Alternative Emergency Strategies

Texas rules allow affected utilities to meet emergency requirements through approved strategies appropriate to the system.

Depending on the current rule and approved EPP, approaches can involve:

• auxiliary generators;
• alternative generation;
• multiple electrical feeds;
• water storage;
• interconnections;
• other approved emergency arrangements.

Follow the Approved EPP

An operator should know which strategy the system actually committed to in its approved plan.

An emergency response should not depend on an undocumented assumption that another option will work.

Emergency Contacts

An EPP contains emergency contact information.

Contacts can include:

• system management;
• operators;
• electric utility;
• generator service provider;
• fuel supplier;
• local emergency management;
• police;
• fire department;
• TCEQ contacts;
• neighboring utilities.

Keep Contact Information Current

An outdated emergency contact list can delay response when minutes matter.

Operators should periodically verify:

• names;
• telephone numbers;
• email addresses;
• after-hours contacts.

Emergency Staffing

TCEQ recommends planning for appropriate staffing before a natural disaster occurs.

This can include:

• adjusted work schedules;
• on-call operators;
• emergency operations crews;
• cleanup crews;
• backup personnel.

Operators May Need to Shelter or Stage Near the Facility

During severe weather, normal travel may be impossible.

A utility should consider how essential staff will safely reach or remain available to critical facilities.

Weatherization

Texas rules include weatherization requirements for critical public water system equipment.

Weatherization helps reduce the risk that severe weather disables:

• source equipment;
• pumps;
• treatment equipment;
• chemical-feed equipment;
• controls;
• other critical facilities.

Freeze Protection

Freeze protection can include:

• insulation;
• heat tracing;
• enclosures;
• space heating;
• draining vulnerable lines;
• protecting instrumentation.

Weatherization Must Be Maintained

Damaged insulation or nonfunctional heaters can defeat the purpose of weatherization.

Operators should inspect protective equipment before severe weather.

Prepare Before the Event

TCEQ recommends preparing the public water system before a natural disaster strikes.

Useful actions include:

• reviewing emergency plans;
• checking contact information;
• testing emergency generators;
• checking fuel;
• checking chemical inventory;
• checking storage;
• checking communications;
• planning staff coverage.

Chemical Inventory

A system can have power and pressure but still lose treatment capability if critical chemicals are unavailable.

Operators should review inventories of:

• disinfectants;
• coagulants;
• pH adjustment chemicals;
• other treatment chemicals.

Supply-Chain Disruptions

Severe weather can interrupt deliveries.

Operators and management should consider how long existing supplies can support operation.

Communications

Emergency communication must continue even when normal systems fail.

Potential backup methods can include:

• mobile phones;
• radios;
• satellite communications;
• alternate internet connections;
• other system-specific methods.

SCADA and Telemetry

Modern public water systems often depend on SCADA and telemetry.

During an emergency, operators should be prepared for:

• loss of communications;
• loss of remote control;
• incorrect instrumentation;
• cybersecurity incidents;
• need for manual operation.

Know How to Operate Manually

An operator should understand how critical equipment can be operated safely if automation or remote control is unavailable.

Cybersecurity and Resiliency

Cybersecurity is part of modern water-system resiliency because control and communication systems can affect:

• pumps;
• chemical feed;
• tank levels;
• alarms;
• remote operations.

Do Not Ignore an Unexplained SCADA Change

An unexpected command, setpoint, or equipment response should be investigated.

The cause may be:

• instrument failure;
• communication failure;
• operator error;
• control-system problem;
• cyber incident.

Water Quality During Emergencies

Maintaining pressure alone does not guarantee safe water.

Operators must also protect:

• disinfection;
• treatment performance;
• storage sanitation;
• distribution integrity.

Pressure Loss

If system pressure is lost or substantially reduced, operators should evaluate whether contamination may have entered the distribution system.

Actions can include:

• isolating affected areas;
• restoring pressure;
• flushing;
• disinfection;
• sampling;
• public notification.

Boil Water Notices

An emergency can create conditions requiring a boil water notice.

Operators should follow current TCEQ requirements for:

• issuance;
• customer communication;
• TCEQ notification;
• corrective action;
• sampling;
• rescission.

Sampling During Emergencies

Severe weather and disasters can interfere with normal compliance sampling.

TCEQ advises systems to contact the Public Drinking Water Program when a sampling schedule needs adjustment.

Operators should not simply skip a required sample without communication.

Emergency Event Documentation

Operators should document significant emergency conditions, including:

• time power was lost;
• generator startup;
• pressure;
• storage level;
• equipment failures;
• water-quality measurements;
• corrective actions;
• notifications;
• time normal operation was restored.

Recovery Is Part of Emergency Response

Restoring electrical power does not automatically mean the emergency is over.

Operators should verify:

• treatment performance;
• distribution pressure;
• storage condition;
• disinfectant residual;
• instrument accuracy;
• equipment condition.

Restarting Treatment Equipment

After a shutdown, equipment should be restarted according to safe operating procedures.

Operators should consider:

• chemical-feed priming;
• pump condition;
• filter condition;
• instrument calibration;
• disinfection;
• appropriate flushing.

Inspect Facilities After Severe Weather

After a storm, flood, freeze, or other event, inspect critical facilities for:

• physical damage;
• electrical damage;
• leaks;
• chemical releases;
• damaged vents or screens;
• security problems;
• contamination.

Flooding

Floodwater can affect:

• wells;
• electrical equipment;
• chemical storage;
• treatment facilities;
• distribution infrastructure.

A flooded facility should be evaluated before normal operation resumes.

Well Flooding

If floodwater reaches a well or creates a contamination risk, the operator should follow appropriate procedures for:

• inspection;
• disinfection;
• flushing;
• sampling;
• return to service.

Emergency Mutual Aid

Utilities can improve resiliency by arranging mutual assistance before an emergency.

Assistance can involve:

• personnel;
• pumps;
• generators;
• repair equipment;
• parts;
• technical support.

TxWARN

Texas utilities can participate in the Texas Water/Wastewater Agency Response Network, or TxWARN, to support mutual aid and emergency response.

Do Not Wait Until the Disaster to Establish Mutual Aid

Pre-event participation improves the ability to request and coordinate assistance when local resources are overwhelmed.

Operator Resiliency Training Is Separate

Texas water operators also have individual resiliency-training requirements for occupational licensing and continuing education.

Those requirements are separate from the public water system's EPP and emergency-operation responsibilities.

System EPP Versus Operator Training

A useful distinction is:

• operator resiliency training applies to the individual license holder;
• the EPP applies to the affected utility and its ability to maintain service.

Completing operator CE does not satisfy the utility's EPP requirement.

Likewise, having an approved EPP does not satisfy an operator's individual resiliency-training requirement.

Example: Power Failure Lasts Four Hours

The operator should implement the appropriate emergency procedures even though the special statutory extended-outage threshold is based on outages lasting 24 hours or more.

A short outage can still create serious operational problems.

Example: Power Failure Lasts 30 Hours

An affected utility must be able to implement its approved emergency strategy and maintain the applicable emergency pressure.

The operator should monitor:

• generator operation;
• fuel;
• pressure;
• storage;
• water quality;
• critical equipment.

Example: Affected Utility Outside Harris County

The applicable emergency-pressure requirement is generally at least 20 psi during the extended power outage condition.

Example: Affected Utility in Harris County

The applicable emergency-pressure requirement is 35 psi during the extended outage condition.

Example: Restaurant with No Overnight Occupancy

A restaurant can be a public water system while not necessarily meeting the affected-utility definition for the EPP requirement.

The system should verify its actual regulatory status rather than assuming all PWS requirements are identical.

Example: Hotel

A hotel provides overnight accommodations and can meet the affected-utility definition.

The system must satisfy applicable EPP requirements.

Example: Generator Starts but Cannot Carry the Pump Load

The emergency power system is not performing its intended function.

This illustrates why generators should be tested under realistic operating load.

Example: Generator Has Only Eight Hours of Fuel

An emergency strategy intended for an extended outage needs a practical plan for continued fuel availability.

Example: SCADA Communication Is Lost

The operator should use approved manual or local operating procedures and verify critical conditions directly where necessary.

Example: Pressure Falls Below the Emergency Requirement

The operator should:

1. identify the cause;
2. restore pumping or emergency supply;
3. evaluate possible contamination;
4. follow applicable notification procedures;
5. document the event.

Example: Severe Freeze Is Forecast

Before the freeze, operators should review:

• weatherization;
• heaters;
• insulation;
• generators;
• fuel;
• chemical inventory;
• staffing;
• communications.

Common Emergency Preparedness Mistakes

• Assuming every PWS has identical EPP requirements.
• Confusing affected-utility status with general PWS classification.
• Keeping an EPP that does not match actual facilities.
• Failing to maintain emergency generators.
• Failing to test generators under load.
• Having inadequate fuel for an extended outage.
• Assuming stored water can reach customers without pumping.
• Failing to update emergency contacts.
• Ignoring water quality while concentrating only on pressure.
• Confusing operator resiliency CE with the system EPP requirement.

A Practical Pre-Emergency Review

1. Review the current EPP.
2. Verify affected-utility requirements.
3. Verify emergency-pressure requirements.
4. Test generators.
5. Check fuel.
6. Check weatherization.
7. Check chemical inventory.
8. Review storage.
9. Verify emergency contacts.
10. Review staff assignments.
11. Verify communications.

A Practical Power-Outage Review

1. Confirm loss of normal power.
2. Start or verify emergency power.
3. Verify critical treatment equipment.
4. Monitor pressure.
5. Monitor storage.
6. Monitor disinfectant residual.
7. Monitor treatment performance.
8. Track fuel supply.
9. Document significant events.
10. Communicate changing conditions.

A Practical Recovery Review

1. Confirm stable electrical service.
2. Return equipment to normal configuration safely.
3. Inspect facilities.
4. Verify treatment performance.
5. Verify pressure.
6. Verify disinfectant residual.
7. Review required flushing or sampling.
8. Complete required notifications.
9. Document the event.
10. Review lessons learned and update procedures when needed.

What to Remember for the Exam

• Texas Emergency Preparedness Plans apply to affected utilities, not automatically to every public water system in exactly the same way.
• Affected utilities generally include systems serving residential customers or providing overnight accommodations and furnishing water to more than one customer.
• An EPP describes how the affected utility will maintain required water service during an extended power outage.
• The extended-outage requirement addresses outages lasting 24 hours or more.
• Affected utilities outside Harris and Fort Bend Counties generally must maintain at least 20 psi during the applicable extended power outage.
• Affected utilities in Harris and Fort Bend Counties must maintain at least 35 psi during the applicable extended power outage.
• Normal operating pressure and emergency minimum pressure are separate concepts.
• An affected utility must submit its EPP to TCEQ for review and approval.
• The approved EPP must reflect the system's actual facilities and emergency strategy.
• Emergency equipment required by the plan must be installed and maintained.
• Generators should be tested and must have adequate capacity and fuel.
• Ground storage generally still requires pumping unless elevation or another approved arrangement provides adequate pressure.
• Emergency interconnections should be tested and understood before an emergency.
• Texas rules require weatherization of critical public water system equipment as applicable.
• Emergency planning includes staffing, communications, chemical supply, equipment, and contact information.
• Maintaining pressure does not eliminate the need to protect disinfection and drinking-water quality.
• Pressure loss can require flushing, disinfection, sampling, public notification, or other corrective actions.
• Operators should document power loss, equipment operation, pressure, water quality, corrective actions, and recovery.
• Operator resiliency training is an individual licensing requirement and is separate from the utility's EPP requirement.
• Emergency preparedness must be maintained continuously, not created only after an emergency occurs.